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...
Chargeability of interest income - interest received in the period prior to commencement of business was in the nature of capital receipt and hence was required to be set off against the pre-operative expenses / project development expenditure - AT
Chargeability of interest income - interest received in the period prior to commencement of business was in the nature of capital receipt and hence was required to be set off against the pre-operative expenses / project development expenditure - AT
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