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...
Revision u/s 263 - unexplained investments - non-initiation of penalty u/s u/s 271(1)(c) of the Act render the order erroneous and prejudicial to the interest of the revenue and upheld the revision u/s 263
Revision u/s 263 - unexplained investments - non-initiation of penalty u/s u/s 271(1)(c) of the Act render the order erroneous and prejudicial to the interest of the revenue and upheld the revision u/s 263
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