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...
Income accrues or arises in India - employer has directly credited the salary, for services rendered outside India, into the NRE bank account of the seafarer in India - The latter remittance would be outside the scope of section 5(2)(a), as what is remitted is not “salary income” but a mere transfer of assessee’s fund from one bank account to another which does not give rise to “Income”.
Income accrues or arises in India - employer has directly credited the salary, for services rendered outside India, into the NRE bank account of the seafarer in India - The latter remittance would be outside the scope of section 5(2)(a), as what is remitted is not “salary income” but a mere transfer of assessee’s fund from one bank account to another which does not give rise to “Income”.
Note: It is a system-generated summary and is for quick reference only.