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 finance cost - borrowings through debentures issued - objection that quantum of borrowing made together with the period of borrowings such rates of interest are highly excessive - Once it has been established through documentary evidence that borrowing has been made through the debentures and utilized for the purpose of business - cost incurred on redemption of debentures is allowable u/s 36(1)(iii)
Disallowance finance cost - borrowings through debentures issued - objection that quantum of borrowing made together with the period of borrowings such rates of interest are highly excessive - Once it has been established through documentary evidence that borrowing has been made through the debentures and utilized for the purpose of business - cost incurred on redemption of debentures is allowable u/s 36(1)(iii)
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
