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 made u/s 40A(2)(b) deleted for the reason that the assessee has proved that the price paid is at arm’s length and not excessive or unreasonable and as the disallowance made on ad-hoc basis is arbitrary. - AT
Disallowance made u/s 40A(2)(b) deleted for the reason that the assessee has proved that the price paid is at arm’s length and not excessive or unreasonable and as the disallowance made on ad-hoc basis is arbitrary. - AT
Note: It is a system-generated summary and is for quick reference only.