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...
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Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
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