Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Rate of tax applicable to PE of foreign entity - DTAA between India and Japan - by virtue of Clause 24(2) of the said agreement and the statutory recognition thereof in Section 90(2), the PE of a Japanese entity(bank) in India could not have been charged tax at a rate higher than comparable Indian assessees carrying on the same activities - taxable @ applicable on Indian bank
Rate of tax applicable to PE of foreign entity - DTAA between India and Japan - by virtue of Clause 24(2) of the said agreement and the statutory recognition thereof in Section 90(2), the PE of a Japanese entity(bank) in India could not have been charged tax at a rate higher than comparable Indian assessees carrying on the same activities - taxable @ applicable on Indian bank
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