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...
Demand of interest and penalty - bonafide belief - Nature of works contract civil contract or construction contract - appellant paid the tax on the basis of 12% later on - The authorities below have committed an error of law and when the tax imposed has already been paid by the appellant, the penalty and interest is therefore not required to be liable to be paid by the appellant. - HC
Demand of interest and penalty - bonafide belief - Nature of works contract civil contract or construction contract - appellant paid the tax on the basis of 12% later on - The authorities below have committed an error of law and when the tax imposed has already been paid by the appellant, the penalty and interest is therefore not required to be liable to be paid by the appellant. - HC
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