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...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
