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...
Prosecution u/s 276-C(1) & 277 - revenue sought additional witness and additional documents - there is no basis to come to a conclusion that respondent (revenue) is adopting dilatory tactics or is in any way harassing petitioner assessee - production of additional witness/documents on record is permissible.
Prosecution u/s 276-C(1) & 277 - revenue sought additional witness and additional documents - there is no basis to come to a conclusion that respondent (revenue) is adopting dilatory tactics or is in any way harassing petitioner assessee - production of additional witness/documents on record is permissible.
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