Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Income received or deemed to be received in India - liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words "collecting information" for the enterprise - liaison office would not qualify to be a permanent establishment in terms of Article 5 of the DTAA - HC
Income received or deemed to be received in India - liaison office is established only for the purpose of carrying on business of purchasing goods for the purpose of export and all that activity also falls within the meaning of the words "collecting information" for the enterprise - liaison office would not qualify to be a permanent establishment in terms of Article 5 of the DTAA - HC
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