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 14A r.w.r. 8D regarding interest expenses - mixed funds used for investments - the condition precedent of recording the requisite satisfaction which is a safeguard provided in Section 14A should not be overlooked before going to Rule 8D - Rule 8D would not be attracted automatically even if mixed funds are used - no disallowance
Addition u/s 14A r.w.r. 8D regarding interest expenses - mixed funds used for investments - the condition precedent of recording the requisite satisfaction which is a safeguard provided in Section 14A should not be overlooked before going to Rule 8D - Rule 8D would not be attracted automatically even if mixed funds are used - no disallowance
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