Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Existence of PE - addition on account of salary reimbursement cost treated as fee for technical services - the burden of proving that the foreign assessee has a PE in India and consequently it has to be taxed on the business generated by such PE is initially on the Revenue. - There will be no income attributable to the PE. - AT
Existence of PE - addition on account of salary reimbursement cost treated as fee for technical services - the burden of proving that the foreign assessee has a PE in India and consequently it has to be taxed on the business generated by such PE is initially on the Revenue. - There will be no income attributable to the PE. - AT
Note: It is a system-generated summary and is for quick reference only.