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...
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Addition of expenses u/s 37(1) - It does not make any difference, whether expenditure is direct or indirect - So long as there exists a nexus of the expenditure with the offence, it will continue to be hit by the Explanation - AT
Addition of expenses u/s 37(1) - It does not make any difference, whether expenditure is direct or indirect - So long as there exists a nexus of the expenditure with the offence, it will continue to be hit by the Explanation - AT
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