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 - voluntarily disallowance made was more than dividend income received - further disallowance made by the AO and confirmed by CIT(A)is not warranted in the facts and circumstances
Disallowance u/s 14A - voluntarily disallowance made was more than dividend income received - further disallowance made by the AO and confirmed by CIT(A)is not warranted in the facts and circumstances
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