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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Consideration for the services under the contracts for provision of cementing services fall under the exclusion and doesn’t qualify as fees for technical services as per explanation to section 9(1)(vii) and in any case, the provisions of section 44BB being more specific, shall be applicable and provisions of section 44DA are not applicable in the instant case. - AT
Consideration for the services under the contracts for provision of cementing services fall under the exclusion and doesn’t qualify as fees for technical services as per explanation to section 9(1)(vii) and in any case, the provisions of section 44BB being more specific, shall be applicable and provisions of section 44DA are not applicable in the instant case. - AT
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