Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Whether tax credit for challans and release/refund of seized cash: Respondents issued fresh Form No. 3 (10.12.2025) and Form No. 5 (11.12.2025), accepting credit for three challans on the basis of reconciled records - consequence: CPC directed to refund the resultant tax amount to the Petitioner within 30 days. Separately, Respondents acknowledged seizure of cash, accepted that records were misplaced with another ward but undertook to refund the seized cash with accumulated interest; Petitioner furnished an indemnity bond - consequence: Respondents directed to refund the seized cash with interest within 30 days. - HC
Whether tax credit for challans and release/refund of seized cash: Respondents issued fresh Form No. 3 (10.12.2025) and Form No. 5 (11.12.2025), accepting credit for three challans on the basis of reconciled records - consequence: CPC directed to refund the resultant tax amount to the Petitioner within 30 days. Separately, Respondents acknowledged seizure of cash, accepted that records were misplaced with another ward but undertook to refund the seized cash with accumulated interest; Petitioner furnished an indemnity bond - consequence: Respondents directed to refund the seized cash with interest within 30 days. - HC
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