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...
Addition of amount shown as “Share Premium” as ‘Income from other sources' - genuineness of the said transaction of purchase of 5 lakh shares of the assessee company @ ₹ 1,000 per share i.e. at a premium of ₹ 990 per share by M/s. Walden Properties Pvt. Ltd. in the year under consideration has not been established - additions confirmed - AT
Addition of amount shown as “Share Premium” as ‘Income from other sources' - genuineness of the said transaction of purchase of 5 lakh shares of the assessee company @ ₹ 1,000 per share i.e. at a premium of ₹ 990 per share by M/s. Walden Properties Pvt. Ltd. in the year under consideration has not been established - additions confirmed - AT
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