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...
Bogus claim of consultancy charges payments - providing accommodation entries - Once the assessee admitted that ₹ 50 lakhs was claimed excessively, the onus of showing that the balance ₹ 50 lakhs was a justified expenditure lay upon it. - Additions confirmed - HC
Bogus claim of consultancy charges payments - providing accommodation entries - Once the assessee admitted that ₹ 50 lakhs was claimed excessively, the onus of showing that the balance ₹ 50 lakhs was a justified expenditure lay upon it. - Additions confirmed - HC
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