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...
Reopening of assessment - the two parts of Section 147 (one relating to 'such income' and the other to 'any other income') are to be read independently - addition can be made on other income even if no addition made for the such income with regard to which reasons have been recorded - HC
Reopening of assessment - the two parts of Section 147 (one relating to 'such income' and the other to 'any other income') are to be read independently - addition can be made on other income even if no addition made for the such income with regard to which reasons have been recorded - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
