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...
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Disallowance of cost of construction - Since only provisions of 40A(3) are invoked, there is no question of treating the expenditure as 'non-genuine' as no amount was disallowed u/s. 37(1). Provisions of Section 40A(3) can only be invoked on the expenditure which was paid in cash - AT
Disallowance of cost of construction - Since only provisions of 40A(3) are invoked, there is no question of treating the expenditure as 'non-genuine' as no amount was disallowed u/s. 37(1). Provisions of Section 40A(3) can only be invoked on the expenditure which was paid in cash - AT
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