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...
Reassessment proceedings alleging fictitious mutual-fund losses and dividend income were quashed where the taxpayer was identically situated to one covered by a final earlier decision and the Revenue did not dispute its applicability. The order under section 148A(d) and the notice under section 148 were set aside because the earlier ruling had already quashed materially similar reassessment action on identical facts.
Reassessment proceedings alleging fictitious mutual-fund losses and dividend income were quashed where the taxpayer was identically situated to one covered by a final earlier decision and the Revenue did not dispute its applicability. The order under section 148A(d) and the notice under section 148 were set aside because the earlier ruling had already quashed materially similar reassessment action on identical facts.
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TaxTMI 
TaxTMI 
of 4910 
