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...
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
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TaxTMI 
TaxTMI 
of 4878 
