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...
Charitable trust - Validity of subsequent SCN invoking the extended period - deliberate defiance and the intention to avoid and evade the taxes were noticed - extended period has been rightly invoked - demand confirmed with penalty - AT
Charitable trust - Validity of subsequent SCN invoking the extended period - deliberate defiance and the intention to avoid and evade the taxes were noticed - extended period has been rightly invoked - demand confirmed with penalty - AT
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