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...
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
