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...
Operation and Maintenance Management of Well Stimulation Vessel - Classification of service in question under ‘Ship Management Service' under Section 65(95a) upheld - The service provided during the disputed period from 16.06.2005 to 31.03.2006, is not taxable, being composite service, and cannot be vivisected - Refund allowed - AT
Operation and Maintenance Management of Well Stimulation Vessel - Classification of service in question under ‘Ship Management Service' under Section 65(95a) upheld - The service provided during the disputed period from 16.06.2005 to 31.03.2006, is not taxable, being composite service, and cannot be vivisected - Refund allowed - AT
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