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...
Mandatory procedure u/s 260A - scope and procedure to adopted by the HC u/s 260A - The appeal is heard on merits only on the questions framed by the High Court u/s 260A(3) provided u/s 260A(4) - If the High Court was of the view that the appeal did not involve any substantial question of law, it should have recorded a categorical finding and should have dismissed the appeal in limine.
Mandatory procedure u/s 260A - scope and procedure to adopted by the HC u/s 260A - The appeal is heard on merits only on the questions framed by the High Court u/s 260A(3) provided u/s 260A(4) - If the High Court was of the view that the appeal did not involve any substantial question of law, it should have recorded a categorical finding and should have dismissed the appeal in limine.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
