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...
Non-deduction of TDS u/s 195 - expenses incurred by the assessee to International Project Services Oy. (IPS) - Since the relevant information for ascertaining the duration of stay of such residents of Finland in India is not available on record, matter remanded back - AT
Non-deduction of TDS u/s 195 - expenses incurred by the assessee to International Project Services Oy. (IPS) - Since the relevant information for ascertaining the duration of stay of such residents of Finland in India is not available on record, matter remanded back - AT
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