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...
Adding net profit and share premium sum u/s 68 - there can be no straitjacket formula for determining share premium which depends upon current strength and future potential of an enterprise. - failure to discharge of onus by assessee - additions confirmed - AT
Adding net profit and share premium sum u/s 68 - there can be no straitjacket formula for determining share premium which depends upon current strength and future potential of an enterprise. - failure to discharge of onus by assessee - additions confirmed - AT
Note: It is a system-generated summary and is for quick reference only.