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...
Section 69A was considered in relation to income from other sources that had been included in taxable income and on which advance tax, tax deducted at source and self-assessment tax had been paid, but which was omitted from the corresponding return schedule. The material also addresses appeal limitation where High Court directions permitted filing without reference to limitation and required exclusion of the period of pendency.
Section 69A was considered in relation to income from other sources that had been included in taxable income and on which advance tax, tax deducted at source and self-assessment tax had been paid, but which was omitted from the corresponding return schedule. The material also addresses appeal limitation where High Court directions permitted filing without reference to limitation and required exclusion of the period of pendency.
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