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...
Penalty u/s 27ID - cash loans exceeding ₹ 20,000 from agriculturists - since the creditor had given the loan from their agricultural income and the borrower was also engaged in agricultural activity, the provisions of section 269SS are not attracted, has not been verified by the AO as well as by the CIT(A) from the perusal of the evidences, matter remanded back.
Penalty u/s 27ID - cash loans exceeding ₹ 20,000 from agriculturists - since the creditor had given the loan from their agricultural income and the borrower was also engaged in agricultural activity, the provisions of section 269SS are not attracted, has not been verified by the AO as well as by the CIT(A) from the perusal of the evidences, matter remanded back.
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