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...
Addition under the head of 'fraud payment'- The failure by the Assessee's employees to do so resulted in a legal liability on the Assessee to make good the loss to IHCL - claim of expnediture u/s 37 allowed - HC
Addition under the head of 'fraud payment'- The failure by the Assessee's employees to do so resulted in a legal liability on the Assessee to make good the loss to IHCL - claim of expnediture u/s 37 allowed - HC
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