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...
Management and advisory fees - Business income or income from other sources - AO has not been able to prove that the appellant did not carry out the stated activity of investment management - HC
Management and advisory fees - Business income or income from other sources - AO has not been able to prove that the appellant did not carry out the stated activity of investment management - HC
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