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 271B - delay in submitting audit report - AO has not given any adverse finding that it affected the proper computation of income - the breach remains a technical breach of the procedural requirement - No penalty - AT
Penalty u/s 271B - delay in submitting audit report - AO has not given any adverse finding that it affected the proper computation of income - the breach remains a technical breach of the procedural requirement - No penalty - AT
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