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...
Supply of manpower to job-worker - the assessee has been utilizing his own labour for packing activities. Viewed in this light, we are not able to appreciate how tax can be levied on the assessee for utilizing his own labour - tax liability do not sustain - AT
Supply of manpower to job-worker - the assessee has been utilizing his own labour for packing activities. Viewed in this light, we are not able to appreciate how tax can be levied on the assessee for utilizing his own labour - tax liability do not sustain - AT
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