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...
Input tax credit on expenses attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in furtherance of the company's business. Services used to raise capital for expansion, capital expenditure, working capital, repayment of borrowings and other business purposes have a substantial nexus with business operations and do not fall within blocked credits. In contrast, credit is unavailable for expenses attributable to an offer for sale by existing shareholders because those proceeds accrue to the shareholders rather than the company.
Input tax credit on expenses attributable to the fresh issue component of an initial public offering is available where the net proceeds are used in furtherance of the company's business. Services used to raise capital for expansion, capital expenditure, working capital, repayment of borrowings and other business purposes have a substantial nexus with business operations and do not fall within blocked credits. In contrast, credit is unavailable for expenses attributable to an offer for sale by existing shareholders because those proceeds accrue to the shareholders rather than the company.
Note: It is a system-generated summary and is for quick reference only.