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...
Filing of appeal before the tribunal - Reviewing committee of two commissioners - one officer who is in-charge of both the Commissionerates - defect if any is procedural and an irregularity and not illegality.
Filing of appeal before the tribunal - Reviewing committee of two commissioners - one officer who is in-charge of both the Commissionerates - defect if any is procedural and an irregularity and not illegality.
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