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...
Levy of interest u/s 201(1A) - failure to deduct TDS u/s 194J - payments made by the assessee herein have been included in the income of the deductees and taxes paid thereon. - There is no choice available to the revenue and interest u/s 201(1A) is to be mandatorily charged for the delayed period of remittance and is automatic in nature.
Levy of interest u/s 201(1A) - failure to deduct TDS u/s 194J - payments made by the assessee herein have been included in the income of the deductees and taxes paid thereon. - There is no choice available to the revenue and interest u/s 201(1A) is to be mandatorily charged for the delayed period of remittance and is automatic in nature.
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