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...
Denial of input tax credit solely on the ground of belated filing of returns was held unsustainable where the taxpayer can substantiate entitlement through requisite documents. The authority was directed to consider the statutory intervention permitting regularisation of the default in return filing and to pass appropriate orders to regularise the lapse upon verification of supporting records. The taxpayer was also permitted to move a supplementary rectification application against the impugned order, which the authority must decide in accordance with law. Petition disposed of with these directions - HC
Denial of input tax credit solely on the ground of belated filing of returns was held unsustainable where the taxpayer can substantiate entitlement through requisite documents. The authority was directed to consider the statutory intervention permitting regularisation of the default in return filing and to pass appropriate orders to regularise the lapse upon verification of supporting records. The taxpayer was also permitted to move a supplementary rectification application against the impugned order, which the authority must decide in accordance with law. Petition disposed of with these directions - HC
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TaxTMI 
TaxTMI 
of 4879 
