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...
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
