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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Upper turnover filter of Rs. 200 crore for selecting software-development comparables in transfer-pricing analysis was treated as valid under precedent. The Revenue's challenge failed because the issue was already covered in favour of the taxpayer, resulting in dismissal of its appeal for the relevant assessment year.
Upper turnover filter of Rs. 200 crore for selecting software-development comparables in transfer-pricing analysis was treated as valid under precedent. The Revenue's challenge failed because the issue was already covered in favour of the taxpayer, resulting in dismissal of its appeal for the relevant assessment year.
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