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...
Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in assessment order in respect of certain additions and not recorded in respect of certain other additions; it acts as a bar against levy of penalty U/s 271(1)(c) in respect of those additions in respect of which such satisfaction was not recorded in the assessment order or during the assessment proceedings
Penalty u/s 271(1)(c) - non recording of satisfaction - When satisfaction for initiation of penalty proceedings u/s 271(1)(c) of IT Act is recorded by the AO in assessment order in respect of certain additions and not recorded in respect of certain other additions; it acts as a bar against levy of penalty U/s 271(1)(c) in respect of those additions in respect of which such satisfaction was not recorded in the assessment order or during the assessment proceedings
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
