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...
Penalty u/s 271(1)(c) - survey team did not make further enquiries nor was it established that these represented any other income - the amount disclosed during the survey was duly included in the original return of income filed after the date of survey hence there is no difference as such in the return of income and assessed income - no penalty
Penalty u/s 271(1)(c) - survey team did not make further enquiries nor was it established that these represented any other income - the amount disclosed during the survey was duly included in the original return of income filed after the date of survey hence there is no difference as such in the return of income and assessed income - no penalty
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
