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 court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
The court held that where the subject matter relates to different financial years, a composite intimation and single show-cause notice are impermissible: separate intimations and, after considering statutory replies, separate DRC-01 show-cause proceedings are required - consequence: the impugned intimation and show-cause notice are quashed and set aside. The court permitted respondents liberty to reinitiate proceedings lawfully and to take appropriate action on or before 15.1.2026, and directed that any adjudication thereafter be completed within a reasonable time but not later than 31.3.2026. - HC
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TaxTMI 
TaxTMI 
of 4894 
