Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Where an appellant cannot upload an appeal on the common electronic portal because the portal refuses filing absent deposit of a separate demand item, the office must accept a manually filed appeal; the core legal point is that a technical or procedural barrier on the e filing system that prevents initiation of an appeal constitutes a valid ground for manual presentation and obliges the appellate authority to receive and process the appeal manually.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
