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...
Withholding the refund of excess amount - In the absence of any assessment for the year 2011-2012 and more particularly, when the time period for completion of assessment is over as prescribed under the provisions of Section 34(9) and 34(10) of the Act, 2003, the respondents are not entitled to withhold the refund.
Withholding the refund of excess amount - In the absence of any assessment for the year 2011-2012 and more particularly, when the time period for completion of assessment is over as prescribed under the provisions of Section 34(9) and 34(10) of the Act, 2003, the respondents are not entitled to withhold the refund.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
