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...
Valuation of goods manufactured by the appellant and transferred to their sister unit - when total is calculated the difference works out to negligible amount. There was some difference of opinion regarding allocation of overhead expenses - no ground for imposing penalty - AT
Valuation of goods manufactured by the appellant and transferred to their sister unit - when total is calculated the difference works out to negligible amount. There was some difference of opinion regarding allocation of overhead expenses - no ground for imposing penalty - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
