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...
Interest paid to partners disallowed - The assessee has not furnished any evidence with reference to advancement of capital - claim of interest u/s 40(b) cannot be allowed - AT
Interest paid to partners disallowed - The assessee has not furnished any evidence with reference to advancement of capital - claim of interest u/s 40(b) cannot be allowed - AT
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