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...
Rectification u/s 254 - A binding decision is always retrospective - When a court decides a matter it only interprets law and applies it to the facts of the case. any interpretation of law contrary to subsequent judicial pronouncement it is a mistake apparent from record.
Rectification u/s 254 - A binding decision is always retrospective - When a court decides a matter it only interprets law and applies it to the facts of the case. any interpretation of law contrary to subsequent judicial pronouncement it is a mistake apparent from record.
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