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...
Penalty u/s 271(1)(c) – Disallowance on account of loss on assets written off and on software expenses – Absence of due care does not mean that the assessee is guilty of either furnishing of inaccurate particulars or attempting to conceal its income - AT
Penalty u/s 271(1)(c) – Disallowance on account of loss on assets written off and on software expenses – Absence of due care does not mean that the assessee is guilty of either furnishing of inaccurate particulars or attempting to conceal its income - AT
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