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...
Classification - Annual technical support fee - Consulting Engineers' Service or Intellectual property services (IPR) - not taxable as consulting engineer's service - AT
Classification - Annual technical support fee - Consulting Engineers' Service or Intellectual property services (IPR) - not taxable as consulting engineer's service - AT
Note: It is a system-generated summary and is for quick reference only.