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...
Retrospective amendment - curtailment of the sales tax incentives by way of deferral – constitutional validity - impact on completed assessment - The amended provisions cannot be invoked and applied in the present factual controversy. - HC
Retrospective amendment - curtailment of the sales tax incentives by way of deferral – constitutional validity - impact on completed assessment - The amended provisions cannot be invoked and applied in the present factual controversy. - HC
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