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...
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Penalty u/s. 271AAA(2) - Assessment u/s 153 - where the revenue had failed to question the assessee while recording the statement u/s 132(4) of the Act as regards the manner of deriving such income, it cannot jump to the consequential or laster requirement of substantiating the manner of deriving the income.
Penalty u/s. 271AAA(2) - Assessment u/s 153 - where the revenue had failed to question the assessee while recording the statement u/s 132(4) of the Act as regards the manner of deriving such income, it cannot jump to the consequential or laster requirement of substantiating the manner of deriving the income.
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