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...
Deemed dividend u/s 2(22)(e) - nature of receipt of sum from a company in which assessee is having 25.24% holding - assessee’s case that the same formed part of transactions in mutual or current account - assessee claimed that it was not loan or advance - the contention of the assessee accepted.
Deemed dividend u/s 2(22)(e) - nature of receipt of sum from a company in which assessee is having 25.24% holding - assessee’s case that the same formed part of transactions in mutual or current account - assessee claimed that it was not loan or advance - the contention of the assessee accepted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
