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...
Extended period of limitation - It is on record that the demand has been raised as per the audit objection and the entire activity of appellant was known to the department - the entire demand is also time barred by limitation of period.
Extended period of limitation - It is on record that the demand has been raised as per the audit objection and the entire activity of appellant was known to the department - the entire demand is also time barred by limitation of period.
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