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...
Transfer of shares for Failure to comply with the conditions of contract - If the transfer was conditional and if the Assessee fails to comply with conditions and therefore, the shares could not be transferred in his name, then, applicability of Section 28(iv) of the Income Tax Act, 1961 is ruled out. - SC dismissed the SLP
Transfer of shares for Failure to comply with the conditions of contract - If the transfer was conditional and if the Assessee fails to comply with conditions and therefore, the shares could not be transferred in his name, then, applicability of Section 28(iv) of the Income Tax Act, 1961 is ruled out. - SC dismissed the SLP
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