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...
Penalty proceedings u/s 271(1)(b) - non-compliance of statutory notices - it was difficult to comply to the various notices on short dates - compliances had been made through replies filed through dak or registered post though belatedly - All these facts and circumstances under any prudence do constitute reasonable cause u/s 273B - No penalty - AT
Penalty proceedings u/s 271(1)(b) - non-compliance of statutory notices - it was difficult to comply to the various notices on short dates - compliances had been made through replies filed through dak or registered post though belatedly - All these facts and circumstances under any prudence do constitute reasonable cause u/s 273B - No penalty - AT
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