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...
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Denying the benefit u/s 91 - Tax Credit - Income accrue in India - assessee being “Resident but not Ordinarily Resident" is not a “Resident in India” - persons who are ‘resident but not ordinarily resident’ in India are forming larger group of the persons who are ‘resident’ in India. - we reject the contentions of the revenue that benefit of section 91 (1) of the act does not apply to a person who is ‘not ordinarily resident’ in India. - AT
Denying the benefit u/s 91 - Tax Credit - Income accrue in India - assessee being “Resident but not Ordinarily Resident" is not a “Resident in India” - persons who are ‘resident but not ordinarily resident’ in India are forming larger group of the persons who are ‘resident’ in India. - we reject the contentions of the revenue that benefit of section 91 (1) of the act does not apply to a person who is ‘not ordinarily resident’ in India. - AT
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