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...
Disallowance of carry forward of losses on the ground that return of income was not filed within the due date as required u/s 139(1) - Mere delay in submitting the ITR-V does not make the return invalid for denying the benefit of carry forward of losses in future years. - AT
Disallowance of carry forward of losses on the ground that return of income was not filed within the due date as required u/s 139(1) - Mere delay in submitting the ITR-V does not make the return invalid for denying the benefit of carry forward of losses in future years. - AT
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