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 capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
Disallowance of capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
