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...
Reference made to Valuation Officer u/s 142A(1) - AO merely acted under the directives of the superior and did not, on his own application of mind, desire to call for the report - reference is not valid - HC
Reference made to Valuation Officer u/s 142A(1) - AO merely acted under the directives of the superior and did not, on his own application of mind, desire to call for the report - reference is not valid - HC
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