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...
Court exercised discretionary relief despite expiry of limitation under Section 107 by quashing and remitting the tax order for fresh adjudication on merits. The writ is disposed subject to the petitioner depositing 25% of the disputed tax as a pre-deposit condition for de novo proceedings; bank attachment is ordered to be vacated on compliance and provided no other arrears exist. Amounts already recovered or paid will be verified and set off against the 25% pre-deposit; if recovered amounts exceed 25% no further payment is required. Noncompliance permits respondents to resume recovery as if the writ were dismissed.
Court exercised discretionary relief despite expiry of limitation under Section 107 by quashing and remitting the tax order for fresh adjudication on merits. The writ is disposed subject to the petitioner depositing 25% of the disputed tax as a pre-deposit condition for de novo proceedings; bank attachment is ordered to be vacated on compliance and provided no other arrears exist. Amounts already recovered or paid will be verified and set off against the 25% pre-deposit; if recovered amounts exceed 25% no further payment is required. Noncompliance permits respondents to resume recovery as if the writ were dismissed.
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TaxTMI 
TaxTMI 
of 4879 
