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...
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Penalty levied u/s 271E - period of limitation - The order of reassessment was not subject matter of revision proceedings u/s 263 or 264 of the Act. Hence the assessee’s case squarely falls under clause (c ) of section 275(1).
Penalty levied u/s 271E - period of limitation - The order of reassessment was not subject matter of revision proceedings u/s 263 or 264 of the Act. Hence the assessee’s case squarely falls under clause (c ) of section 275(1).
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