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...
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Import of services - are branches and head offices separate entities so as to attract service tax on outflow by head office to branches? - The transfer of funds by gross outflow or by netted inflow is nothing but reimbursements and taxing of such reimbursement would amount to taxing of transfer of funds which is not contemplated by Finance Act, 1994 - AT
Import of services - are branches and head offices separate entities so as to attract service tax on outflow by head office to branches? - The transfer of funds by gross outflow or by netted inflow is nothing but reimbursements and taxing of such reimbursement would amount to taxing of transfer of funds which is not contemplated by Finance Act, 1994 - AT
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