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...
TDS u/s 194C or 194I - No basis for confining the effect of the words “other agreement or arrangement for the use of“ “either separately or together“ in regard to the machinery, only if it is part of immovable property. - HC
TDS u/s 194C or 194I - No basis for confining the effect of the words “other agreement or arrangement for the use of“ “either separately or together“ in regard to the machinery, only if it is part of immovable property. - HC
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