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...
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Condonation of delay - it filed appeal against the assessment order instead of 154 order passed by the Assessing Officer because the scope in challenging the assessment order in appeal is far more wider than challenging the order passed under Section 154 of the Income-tax Act for rectification of any mistake. Since the assessee has availed one of the courses available to it and this has made its appeal time barred, it is a plausible explanation for condonation of delay. - Delay condoned - AT
Condonation of delay - it filed appeal against the assessment order instead of 154 order passed by the Assessing Officer because the scope in challenging the assessment order in appeal is far more wider than challenging the order passed under Section 154 of the Income-tax Act for rectification of any mistake. Since the assessee has availed one of the courses available to it and this has made its appeal time barred, it is a plausible explanation for condonation of delay. - Delay condoned - AT
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