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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
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