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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Permanent Establishment (‘PE’) in India - income accrued in India - the profits of the PE should be determined on the basis of what an independent enterprise under similar circumstances might be expected to derive on its own- AT
Permanent Establishment (‘PE’) in India - income accrued in India - the profits of the PE should be determined on the basis of what an independent enterprise under similar circumstances might be expected to derive on its own- AT
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