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...
Reassessment - assessee did not place his wiliness or desire before the AO after receipt of notice u/s 148 of the Act until completion of reassessment proceedings on 27.11.2009, seeking copy of reasons recorded, therefore, the assessee is not entitled for any benefit in this regard - AT
Reassessment - assessee did not place his wiliness or desire before the AO after receipt of notice u/s 148 of the Act until completion of reassessment proceedings on 27.11.2009, seeking copy of reasons recorded, therefore, the assessee is not entitled for any benefit in this regard - AT
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