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...
Validity of Search and seizure - conversion of survey in search - provisions of Section 131(1) could be invoked only if some proceedings were pending - nowhere any satisfaction recorded either of noncooperation or a suspicion that income has been concealed by the petitioner warranting resort to the process of search and seizure - the impugned action of the respondents is quashed
Validity of Search and seizure - conversion of survey in search - provisions of Section 131(1) could be invoked only if some proceedings were pending - nowhere any satisfaction recorded either of noncooperation or a suspicion that income has been concealed by the petitioner warranting resort to the process of search and seizure - the impugned action of the respondents is quashed
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