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...
Misclassification due to suppression of facts – Imposition of penalty – Settlement Commission ought to be aware of ramifications of imposing penalty – Commission failed to apply its mind to this important aspect of matter and court constrained to set aside order passed by Commission to this limited extent - HC
Misclassification due to suppression of facts – Imposition of penalty – Settlement Commission ought to be aware of ramifications of imposing penalty – Commission failed to apply its mind to this important aspect of matter and court constrained to set aside order passed by Commission to this limited extent - HC
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