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...
Intellectual Property Rights - whether the manufacturing/tie up based agreement entered into by the appellant-assessee with bottlers can be considered as agreement for payment of royalty by the bottlers to the appellant-assessee liable to service tax - Held No - AT
Intellectual Property Rights - whether the manufacturing/tie up based agreement entered into by the appellant-assessee with bottlers can be considered as agreement for payment of royalty by the bottlers to the appellant-assessee liable to service tax - Held No - AT
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