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...
Petitioner proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
Petitioner proved payment of GST by documentary verification from the tax authority and submitted a supplementary agreement; respondents' refusal to reimburse on account of a final bill and a no-claim certificate was found legally unsustainable. The supplementary agreement, though not executed by the respondent, was presented with due signature and cannot be imputed as petitioner's fault, and parallel administrative acceptances of similar claims were noted. Operatively, the petitioner is entitled to GST neutralisation and the department is directed to accept the claim and reimburse the GST amount as due.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
