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...
Reopening of assessment u/s 147 - service of notice - there is no power of attorney of CA given by the assessee, therefore, in such circumstances even if any notice was served on CA u/s 148 but the same is of no consequence in the absence of any valid authority/authorization given by the assessee company to the said CA.
Reopening of assessment u/s 147 - service of notice - there is no power of attorney of CA given by the assessee, therefore, in such circumstances even if any notice was served on CA u/s 148 but the same is of no consequence in the absence of any valid authority/authorization given by the assessee company to the said CA.
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