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...
Claim of refund - Revision before the Commissioner u/s 264 in favor of assessee, against in intimation u/s 143(1) - the intimation under Section 143(1) is regarded as an 'order' for the purposes of Section 264 - HC
Claim of refund - Revision before the Commissioner u/s 264 in favor of assessee, against in intimation u/s 143(1) - the intimation under Section 143(1) is regarded as an 'order' for the purposes of Section 264 - HC
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