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...
Estimated the possible profit out of purchases made through non-genuine parties -The estimation of rate of profit return must necessarily vary with the nature of business and no uniform yardstick can be adopted - Disallowance to the extent of 12.5 percent is allowed - HC
Estimated the possible profit out of purchases made through non-genuine parties -The estimation of rate of profit return must necessarily vary with the nature of business and no uniform yardstick can be adopted - Disallowance to the extent of 12.5 percent is allowed - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
