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...
Suo moto re-credit amount in PLA instead of claiming refund - refund is governed by Section 11B - Even in the case of suo moto re-credit though in principle, the appellant is entitled but subject to test of unjust enrichment. - AT
Suo moto re-credit amount in PLA instead of claiming refund - refund is governed by Section 11B - Even in the case of suo moto re-credit though in principle, the appellant is entitled but subject to test of unjust enrichment. - AT
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