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...
Rectification of order U/s 254 - Tribunal gave a certain verdict which may have aggrieved the department and may have also given rise to an arguable legal point. Nevertheless, that by itself would not enable the department to activate the rectification powers of the Tribunal.
Rectification of order U/s 254 - Tribunal gave a certain verdict which may have aggrieved the department and may have also given rise to an arguable legal point. Nevertheless, that by itself would not enable the department to activate the rectification powers of the Tribunal.
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