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 made u/s 40A(3) - payment through bearer cheques - payment made otherwise than by cheque or crossed cheque - since the entries in the bank statement reflects the names of two parties and also because of compelling circumstances of the sellers asking for such payment, then we hold that there is no merit in invoking provisions of section 40A(3) to such transactions - AT
Addition made u/s 40A(3) - payment through bearer cheques - payment made otherwise than by cheque or crossed cheque - since the entries in the bank statement reflects the names of two parties and also because of compelling circumstances of the sellers asking for such payment, then we hold that there is no merit in invoking provisions of section 40A(3) to such transactions - AT
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TaxTMI 
TaxTMI 
of 4879 
