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...
Recovery of tax from successor company - The petitioner is estopped from raising such contention at this stage, for the reason that having availed the exemption the petitioner cannot turn around and contend that at this belated stage that the said condition is a nullity being violative of the provisions of the Act or is opposed to public policy - HC
Recovery of tax from successor company - The petitioner is estopped from raising such contention at this stage, for the reason that having availed the exemption the petitioner cannot turn around and contend that at this belated stage that the said condition is a nullity being violative of the provisions of the Act or is opposed to public policy - HC
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