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Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Interest expenditure - Since the basic premise with the revenue for making disallowance in the present case U/s 36(1)(iii) was that the assessee had charged less interest on the advances made to its partners and others as opposed to that paid on borrowings made by it, the same does not survive since the assessee has demonstrated that it had actually paid less interest on borrowings and charged more from the partners and others. In view of the above, the disallowance made U/s 36(1)(iii).
Interest expenditure - Since the basic premise with the revenue for making disallowance in the present case U/s 36(1)(iii) was that the assessee had charged less interest on the advances made to its partners and others as opposed to that paid on borrowings made by it, the same does not survive since the assessee has demonstrated that it had actually paid less interest on borrowings and charged more from the partners and others. In view of the above, the disallowance made U/s 36(1)(iii).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
