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 advances written off - the parent company has not reimbursed the amount only on account of change of policy of the parent company. - the assessee has failed to substantiate as to why the advances amount was written off, particularly under the fact that the same is recoverable from its parent company.
Disallowance of advances written off - the parent company has not reimbursed the amount only on account of change of policy of the parent company. - the assessee has failed to substantiate as to why the advances amount was written off, particularly under the fact that the same is recoverable from its parent company.
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