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...
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
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