Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Fees for technical services received - computation of period of stay - From the wording of the article 5 of DTAA in question, it is not possible to accept the plea of the Revenue that the supervisory activities need not have been carried on for six continuous months. - HC
Fees for technical services received - computation of period of stay - From the wording of the article 5 of DTAA in question, it is not possible to accept the plea of the Revenue that the supervisory activities need not have been carried on for six continuous months. - HC
Note: It is a system-generated summary and is for quick reference only.