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...
Addition u/s 56(2)(vii)(b) - issues of shares at a price more than the FMV - from the year of application or allotment - Section was inserted vide Finance Act, 2013 w.e.f 01.04.2013 - since shares were applied in FY 2012-13 as per the terms and conditions settled, the provision u/s 56(2)(viib) cannot be applied merely on the basis that shares were allotted in FY 2013-14
Addition u/s 56(2)(vii)(b) - issues of shares at a price more than the FMV - from the year of application or allotment - Section was inserted vide Finance Act, 2013 w.e.f 01.04.2013 - since shares were applied in FY 2012-13 as per the terms and conditions settled, the provision u/s 56(2)(viib) cannot be applied merely on the basis that shares were allotted in FY 2013-14
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