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...
Penalty u/s 271D - violation of the provisions of section 269SS or not - treating the deposit/loan of ₹ 40,00,000/- as capital contribution of the member of AOP, for the AOP - transactions are genuine - no penalty - HC
Penalty u/s 271D - violation of the provisions of section 269SS or not - treating the deposit/loan of ₹ 40,00,000/- as capital contribution of the member of AOP, for the AOP - transactions are genuine - no penalty - HC
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