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...
Refund - relevant date - the appellant has admittedly filed the refund claim within one year from the receipt of convertible foreign exchange - the relevant date is the date of FIRC and not the date of service. - AT
Refund - relevant date - the appellant has admittedly filed the refund claim within one year from the receipt of convertible foreign exchange - the relevant date is the date of FIRC and not the date of service. - AT
Note: It is a system-generated summary and is for quick reference only.