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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Disallowance in respect of Hedging Loss - there is no such detail available to show that the alleged transactions entered on the portal of NCDEX were entered to counter or hedge the probable loss from the contract for actual delivery of goods. - To be treated as speculative loss.
Disallowance in respect of Hedging Loss - there is no such detail available to show that the alleged transactions entered on the portal of NCDEX were entered to counter or hedge the probable loss from the contract for actual delivery of goods. - To be treated as speculative loss.
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