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...
Penalty under section 271(1)(c) - The return was revised with a view to co-operate the Department and to buy peace and to avoid litigation. The disclosure was with a specific plea that no penalty proceedings be initiated under section 271AAA or 271(1)(c) - No Penalty - AT
Penalty under section 271(1)(c) - The return was revised with a view to co-operate the Department and to buy peace and to avoid litigation. The disclosure was with a specific plea that no penalty proceedings be initiated under section 271AAA or 271(1)(c) - No Penalty - AT
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