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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Limitation computation treats an objection filed on the next working day as timely where the statutory final day falls on a Sunday. Under section 144C, a timely objection requires the Assessing Officer to await binding Dispute Resolution Panel directions before making a final assessment. Rejection of the objection as time-barred led to the final assessment being quashed, with the objection requiring merits-based consideration after hearing the assessee. Consequential penalty proceedings remain stayed until completion of that adjudication.
Limitation computation treats an objection filed on the next working day as timely where the statutory final day falls on a Sunday. Under section 144C, a timely objection requires the Assessing Officer to await binding Dispute Resolution Panel directions before making a final assessment. Rejection of the objection as time-barred led to the final assessment being quashed, with the objection requiring merits-based consideration after hearing the assessee. Consequential penalty proceedings remain stayed until completion of that adjudication.
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