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...
Validity of notice issued u/s 153C - the seized material found from the premises of the 3rd party in the course of search does not belong to the assessee. Thus in our considered view the proceedings u/s 153C of the Act, cannot be initiated. - AT
Validity of notice issued u/s 153C - the seized material found from the premises of the 3rd party in the course of search does not belong to the assessee. Thus in our considered view the proceedings u/s 153C of the Act, cannot be initiated. - AT
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