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...
Re-opening of assessment u/s 148 - The words of the statute are ‘reason to believe' and not ‘reason to suspect' - The reopening of an assessment is a serious matter and must be used properly - AT
Re-opening of assessment u/s 148 - The words of the statute are ‘reason to believe' and not ‘reason to suspect' - The reopening of an assessment is a serious matter and must be used properly - AT
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