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...
Revision u/s 263 - non-deduction of TDS on salary and commission paid to directors and managers - insufficient enquiry - AO failed to take into account several aspects as highlighted by the Ld. CIT - revision proceedings sustained - AT
Revision u/s 263 - non-deduction of TDS on salary and commission paid to directors and managers - insufficient enquiry - AO failed to take into account several aspects as highlighted by the Ld. CIT - revision proceedings sustained - AT
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