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...
Enhancement of income by CIT(A) u/s 251(2) - no notice of enhancement - the department did not place any evidence to show that the CIT(A) has issued notice for enhancement - the enhancement made by the Ld.CIT(A) is unsustainable
Enhancement of income by CIT(A) u/s 251(2) - no notice of enhancement - the department did not place any evidence to show that the CIT(A) has issued notice for enhancement - the enhancement made by the Ld.CIT(A) is unsustainable
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