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...
Determination of total income - addition to ncome in hands of assessee - actual business was controlled by the assessee and Shri S.J. Baid was only signing the papers as per directions of the assessee. Under these circumstances the substantive addition has been rightly made in the hands of the assessee - AT
Determination of total income - addition to ncome in hands of assessee - actual business was controlled by the assessee and Shri S.J. Baid was only signing the papers as per directions of the assessee. Under these circumstances the substantive addition has been rightly made in the hands of the assessee - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
