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...
The penalty u/s 271(1)(c) was imposed because the assessee did not offer any explanation to the assessing officer in the first instance and then the penalty was sustained because his explanation furnished before the CIT (Appeals) was rejected. - Levy of penalty confirmed - HC
The penalty u/s 271(1)(c) was imposed because the assessee did not offer any explanation to the assessing officer in the first instance and then the penalty was sustained because his explanation furnished before the CIT (Appeals) was rejected. - Levy of penalty confirmed - HC
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