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...
Deemed dividend u/s 2(22)(e) of the Act – Transaction undertaken with other companies – section 2(22)(e) can be invoked only in the hands of the borrowers who were registered shareholders only - AT
Deemed dividend u/s 2(22)(e) of the Act – Transaction undertaken with other companies – section 2(22)(e) can be invoked only in the hands of the borrowers who were registered shareholders only - AT
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