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...
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
