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...
As the amount paid by the assessee to specific persons are taxed in the hands of specific persons at the same rate , disallowance u/s 40A(2)(b) will be meaningless inasmuch as “permitting the Revenue to tax the same income again at the same rate in the hand of principal payer would amount to double taxation".
As the amount paid by the assessee to specific persons are taxed in the hands of specific persons at the same rate , disallowance u/s 40A(2)(b) will be meaningless inasmuch as “permitting the Revenue to tax the same income again at the same rate in the hand of principal payer would amount to double taxation".
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
