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 in the hands of the assessee was made on protective basis which means the AO himself was not confident with respect to the tax liability of the alleged income estimated by him in the hands of the assessee - Additions made by AO deleted - AT
Addition in the hands of the assessee was made on protective basis which means the AO himself was not confident with respect to the tax liability of the alleged income estimated by him in the hands of the assessee - Additions made by AO deleted - AT
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