Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Assessment relating to alleged excess/irregular ITC availment and consequential interest and late-fee liabilities was interfered with on the ground that the matter required reconsideration on merits after a proper reply and supporting documents. The impugned order was directed to be treated as an addendum to the show-cause notice, and the authority was mandated to pass a fresh final order in accordance with law after considering the taxpayer's reply. The remand was made conditional upon deposit of 50% of the disputed tax (in cash through the electronic cash ledger) within 30 days; upon such compliance, the bank-account attachment was to stand automatically vacated and the authority to decide expeditiously. - HC
Assessment relating to alleged excess/irregular ITC availment and consequential interest and late-fee liabilities was interfered with on the ground that the matter required reconsideration on merits after a proper reply and supporting documents. The impugned order was directed to be treated as an addendum to the show-cause notice, and the authority was mandated to pass a fresh final order in accordance with law after considering the taxpayer's reply. The remand was made conditional upon deposit of 50% of the disputed tax (in cash through the electronic cash ledger) within 30 days; upon such compliance, the bank-account attachment was to stand automatically vacated and the authority to decide expeditiously. - HC
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