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...
Disallowance of speculative loss invoking the provisions of section 73 - if the gross total income of the assessee comprises of any or all the heads of income, then the assessee will fall within the exception carved out in the explanation to section 73 and it could not be deemed to be carrying on a speculative business for the purposes of section 73 (1) - assessee shall not be deemed to be carrying on with the speculative business - AT
Disallowance of speculative loss invoking the provisions of section 73 - if the gross total income of the assessee comprises of any or all the heads of income, then the assessee will fall within the exception carved out in the explanation to section 73 and it could not be deemed to be carrying on a speculative business for the purposes of section 73 (1) - assessee shall not be deemed to be carrying on with the speculative business - AT
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