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...
Unabsorbed investment allowance - allowance u/s 32A (6) - AO had to see whether the assessee had fulfilled the conditions of section 32A(6) but he laid emphasis on the provisions of section 72A of the Act, which is misplaced. - The appellant has elaborately shown that the conditions specified in section 32A(6) of the Act are fulfilled by it. Therefore, the claim of the appellant is fully justified.
Unabsorbed investment allowance - allowance u/s 32A (6) - AO had to see whether the assessee had fulfilled the conditions of section 32A(6) but he laid emphasis on the provisions of section 72A of the Act, which is misplaced. - The appellant has elaborately shown that the conditions specified in section 32A(6) of the Act are fulfilled by it. Therefore, the claim of the appellant is fully justified.
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