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...
Disallowance of commission expenses - Though, the payment may be at the convenience of the parties or at the time of availability of funds but the booking the bills after substantial delay proves that these expenditure are not genuine. The confirmation notes and the invoices of brokerage and confirmation note do not prove that services have been rendered.
Disallowance of commission expenses - Though, the payment may be at the convenience of the parties or at the time of availability of funds but the booking the bills after substantial delay proves that these expenditure are not genuine. The confirmation notes and the invoices of brokerage and confirmation note do not prove that services have been rendered.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
