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...
Extended period of limitation - second demand show cause notice, also for the period prior to the date of the visit of the officers, cannot be considered as time barred when the same is issued within a period of five years from the ‘relevant date’ - AT
Extended period of limitation - second demand show cause notice, also for the period prior to the date of the visit of the officers, cannot be considered as time barred when the same is issued within a period of five years from the ‘relevant date’ - AT
Note: It is a system-generated summary and is for quick reference only.