Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Existence of Permanent Establishment (PE) in India or not - India UK DTAA -All the requisite conditions for attracting the mandate of Article 5(2)(k) are satisfied - service PE of the assessee is established in India - AT
Existence of Permanent Establishment (PE) in India or not - India UK DTAA -All the requisite conditions for attracting the mandate of Article 5(2)(k) are satisfied - service PE of the assessee is established in India - AT
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