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...
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Initiation of proceedings u/s 158BD - unless the basic finding is held to be valid, the consequential order is bad in law - since there was no notice served under section 158 BC the assessee could not have been assessed under section 158BD - HC
Initiation of proceedings u/s 158BD - unless the basic finding is held to be valid, the consequential order is bad in law - since there was no notice served under section 158 BC the assessee could not have been assessed under section 158BD - HC
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