Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Whether the payment received by the applicant from the Indian company for services rendered in China is taxable in India under Article 12(4) of DTAA between India and China? - contrast with China-Pakistan tax Treaty - Held Yes - The rate of tax is 10% on the gross amount under the DTAA. - AAR
Whether the payment received by the applicant from the Indian company for services rendered in China is taxable in India under Article 12(4) of DTAA between India and China? - contrast with China-Pakistan tax Treaty - Held Yes - The rate of tax is 10% on the gross amount under the DTAA. - AAR
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