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...
Condonation of delay - No doubt the explanation offered is not convincing but there is nothing on record brought by the Revenue to show that the appellant had purposely and willfully delayed in filing the appeal within the period of limitation - Delay condoned.
Condonation of delay - No doubt the explanation offered is not convincing but there is nothing on record brought by the Revenue to show that the appellant had purposely and willfully delayed in filing the appeal within the period of limitation - Delay condoned.
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