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...
Manufacture - so called activity of quality testing, branding and packing of the already manufactured goods will not be covered by note 6 of Section XVI of the Central Excise Tariff - the appellant is not engaged in the manufacturing of the goods, they are only doing trading activity of bought out goods. - AT
Manufacture - so called activity of quality testing, branding and packing of the already manufactured goods will not be covered by note 6 of Section XVI of the Central Excise Tariff - the appellant is not engaged in the manufacturing of the goods, they are only doing trading activity of bought out goods. - AT
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