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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Nature of non compete fee received by the assessee - CIT(A) has allowed relief to the assessee - Validity of ITAT order in remanding back the matter to CIT(A) - there was no sufficient material before the Tribunal to remand the case for a fresh consideration at the first instance. - The order of remand set aside.
Nature of non compete fee received by the assessee - CIT(A) has allowed relief to the assessee - Validity of ITAT order in remanding back the matter to CIT(A) - there was no sufficient material before the Tribunal to remand the case for a fresh consideration at the first instance. - The order of remand set aside.
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