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...
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
Invocation of extended period of limitation - relevant date u/s 11A - date of knowledge or the date of discovery of the fraud by the Revenue is neither determinative nor decisive - Tribunal's order is ex-facie erroneous and unsustainable in law. It is vitiated by complete non application of mind as well - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
