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...
Addition of principal amount of loan waived by the lender on account of one time settlement of loan - AO was not correct in taxing the aforesaid waiver of loan by treating the same as revenue receipt - AT
Addition of principal amount of loan waived by the lender on account of one time settlement of loan - AO was not correct in taxing the aforesaid waiver of loan by treating the same as revenue receipt - AT
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