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...
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Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.
Tariff-related debit notes seeking reimbursement of income tax as an electricity-tariff component involve disputed questions requiring specialised adjudication before CERC. Writ jurisdiction did not extend to examining the merits of the debit notes or the claimed liability. The generating company was required to pursue the regulatory remedy before CERC, which was to decide the dispute expeditiously after hearing all parties. The writ petition was disposed of on that basis.
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