Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The HC remitted the matter to the respondent for fresh consideration whether the petitioner, who has paid the tax and limited its dispute to imposition of penalty and applicability of machinery provisions, validly contends that proceedings under s. 74 are inappropriate and should have been initiated under s. 73; the respondent is directed to exercise powers under s. 75(2) and complete the re-examination within three months from receipt of this order. The petitioner must file a detailed reply to the notice and treat the impugned order as a show cause notice within 30 days. The petition is disposed of.
The HC remitted the matter to the respondent for fresh consideration whether the petitioner, who has paid the tax and limited its dispute to imposition of penalty and applicability of machinery provisions, validly contends that proceedings under s. 74 are inappropriate and should have been initiated under s. 73; the respondent is directed to exercise powers under s. 75(2) and complete the re-examination within three months from receipt of this order. The petitioner must file a detailed reply to the notice and treat the impugned order as a show cause notice within 30 days. The petition is disposed of.
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TaxTMI 
TaxTMI 
of 4886 
