Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Once a discharge certificate evidencing full and final settlement under s.127 of the Finance (No. 2) Act, 2019 read with Rule 9 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 is issued in Form SVLDRS-4, the department is barred from continuing or completing adjudication on the underlying show cause notice, as the settlement attains finality; any subsequent adjudicatory order is therefore without legal basis and unsustainable. Consequently, the order-in-appeal was set aside and the appeal was allowed. - CESTAT
Once a discharge certificate evidencing full and final settlement under s.127 of the Finance (No. 2) Act, 2019 read with Rule 9 of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 is issued in Form SVLDRS-4, the department is barred from continuing or completing adjudication on the underlying show cause notice, as the settlement attains finality; any subsequent adjudicatory order is therefore without legal basis and unsustainable. Consequently, the order-in-appeal was set aside and the appeal was allowed. - CESTAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
