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...
Rectification of Mistake - Having held that penalty is not imposable, it cannot be held that penalty under Section 78 would be restricted to the extent of confirmation of demand.
Rectification of Mistake - Having held that penalty is not imposable, it cannot be held that penalty under Section 78 would be restricted to the extent of confirmation of demand.
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