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...
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Different view taken by Court - Tribunal has already decided the matter in case of original petitioner - Once a decision has attained finality, it cannot be upset just on a mere ground that subsequently the higher forum has taken a different view - HC
Different view taken by Court - Tribunal has already decided the matter in case of original petitioner - Once a decision has attained finality, it cannot be upset just on a mere ground that subsequently the higher forum has taken a different view - HC
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