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...
Revision u/s 263 - The explanation, as inserted by Finance Act 2015 in Section 263, would come into play only if the primary conditions i.e. order being erroneous and prejudicial to interest of revenue, were fulfilled
Revision u/s 263 - The explanation, as inserted by Finance Act 2015 in Section 263, would come into play only if the primary conditions i.e. order being erroneous and prejudicial to interest of revenue, were fulfilled
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