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Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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