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...
Scope of the order - Order in appeal was common for several parties - Appellants claimed that since the appeals of two of the co-noticees have been allowed and the impugned order of Commissioner (Appeal) has been set aside, there appeal should also be allowed - though the argument look attractive but is without any substance.
Scope of the order - Order in appeal was common for several parties - Appellants claimed that since the appeals of two of the co-noticees have been allowed and the impugned order of Commissioner (Appeal) has been set aside, there appeal should also be allowed - though the argument look attractive but is without any substance.
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