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...
Deduction u/s 80-O - royalties, etc. - Merely for having a contract with a foreign enterprise and mere earning foreign exchange does not ipso facto lead to the application of Section 80-O of the Act. - Circular No.700 is neither of any application to this case nor of any assistance to the appellant
Deduction u/s 80-O - royalties, etc. - Merely for having a contract with a foreign enterprise and mere earning foreign exchange does not ipso facto lead to the application of Section 80-O of the Act. - Circular No.700 is neither of any application to this case nor of any assistance to the appellant
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TaxTMI 
TaxTMI 
of 4886 
