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...
Penalty u/s 271(1)(b) - non-compliance with notices u/s 142(1) - assessee was given very little time to furnish long list of requirements and there was reasonable cause on the part of the assessee for being unable to file the details on the given data in the notice - Penalty set aside - AT
Penalty u/s 271(1)(b) - non-compliance with notices u/s 142(1) - assessee was given very little time to furnish long list of requirements and there was reasonable cause on the part of the assessee for being unable to file the details on the given data in the notice - Penalty set aside - AT
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