Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Disallowance u/s 40(a)(i) – TDS u/s 195 - Liable to tax in the contracting State cannot be implied as the person is actually liable to tax but would also cover the cases where the other contracting State had the right to tax such person - AT
Disallowance u/s 40(a)(i) – TDS u/s 195 - Liable to tax in the contracting State cannot be implied as the person is actually liable to tax but would also cover the cases where the other contracting State had the right to tax such person - AT
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