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...
Indo U.S. DTAA - once the assessee was not a P.E. of VGCs, then “Force of Attraction Rule“ will not apply in terms of Article 7(1) of various DTAA. - AT
Indo U.S. DTAA - once the assessee was not a P.E. of VGCs, then “Force of Attraction Rule“ will not apply in terms of Article 7(1) of various DTAA. - AT
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