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...
Reassessment founded on a share transaction wrongly mapped to an assessee's PAN is unsustainable where the underlying information concerns another person. Initiating proceedings without verification merely to avoid limitation constitutes a colourable exercise of reassessment power. The reassessment order and consequential notice were quashed, and costs were awarded in the proceedings.
Reassessment founded on a share transaction wrongly mapped to an assessee's PAN is unsustainable where the underlying information concerns another person. Initiating proceedings without verification merely to avoid limitation constitutes a colourable exercise of reassessment power. The reassessment order and consequential notice were quashed, and costs were awarded in the proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
