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...
Criminal prosecution – once the Tribunal of a Department holds that there is no concealment of income on part of the accused and the penalty is deleted, the very basis of the complaint is knocked down and continuation of complaint will be an abuse of the process of the Court - HC
Criminal prosecution – once the Tribunal of a Department holds that there is no concealment of income on part of the accused and the penalty is deleted, the very basis of the complaint is knocked down and continuation of complaint will be an abuse of the process of the Court - HC
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