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...
Composite, continuous and inseparable project - computation of table income in India - turnkey project - P.E. in India - allegation of avoidance of tax by splitting the alleged composite contract into three different contracts - the intention of the parties to have three different contracts is proved - there is no wrong intention.
Composite, continuous and inseparable project - computation of table income in India - turnkey project - P.E. in India - allegation of avoidance of tax by splitting the alleged composite contract into three different contracts - the intention of the parties to have three different contracts is proved - there is no wrong intention.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
