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...
Revision u/s 263 - merger of appellate order - very issue which was considered by the CIT(A) and concluded was reopened - no scope for re-examination in the jurisdiction u/s 263 as the assessment order has merged in the appellate order.
Revision u/s 263 - merger of appellate order - very issue which was considered by the CIT(A) and concluded was reopened - no scope for re-examination in the jurisdiction u/s 263 as the assessment order has merged in the appellate order.
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