Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Income accrued in India - AO erred in taxing the service agreement receipt as ‘fee for included services’ as per Article 12(4) of India USA DTAA for such services in absence of clause in the service agreement that the recipient would be able to perform these services of its own without any further assistance of the assessee
Income accrued in India - AO erred in taxing the service agreement receipt as ‘fee for included services’ as per Article 12(4) of India USA DTAA for such services in absence of clause in the service agreement that the recipient would be able to perform these services of its own without any further assistance of the assessee
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