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...
Valuation - includibility - advertisement expenses - the 50% is borne by the dealers/distributors which is the expenses of the dealers/distributors and the appellant is nothing to do with that portion of the 50% - Amount of such advertisement is not flowing to the appellant as an additional consideration. - demand set aside - AT
Valuation - includibility - advertisement expenses - the 50% is borne by the dealers/distributors which is the expenses of the dealers/distributors and the appellant is nothing to do with that portion of the 50% - Amount of such advertisement is not flowing to the appellant as an additional consideration. - demand set aside - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
