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...
Reopening of assessment u/s 147 - denial of deduction u/s 80IB - there were deliberations on the very issue as to whether the activity undertaken by the petitioner amounted to manufacture or not before the respective assessment orders were passed for the respective Assessment Years by the respondent’s predecessor. - Reopening of the assessment to deny the deduction under Section 80IB is therefore without jurisdiction.
Reopening of assessment u/s 147 - denial of deduction u/s 80IB - there were deliberations on the very issue as to whether the activity undertaken by the petitioner amounted to manufacture or not before the respective assessment orders were passed for the respective Assessment Years by the respondent’s predecessor. - Reopening of the assessment to deny the deduction under Section 80IB is therefore without jurisdiction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
