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...
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Penalty u/s 271(1)((c) - Exemption of interest income u/s 80P(2) is not allowable due to subsequent decision - prior to this decision, the position was not clear and issue was debatable - no penalty is leviable
Penalty u/s 271(1)((c) - Exemption of interest income u/s 80P(2) is not allowable due to subsequent decision - prior to this decision, the position was not clear and issue was debatable - no penalty is leviable
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