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...
Assessment u/s 147 - Additions u/s 68 - The regular assessment and block assessment are both separate proceedings and even can run parallel - assessee has failed to substantiate that relevant accommodation entry transactions - we reject the contention of Learned Counsel of the assessee seeking telescoping of the addition with the income already assessed in the block assessment order. - AT
Assessment u/s 147 - Additions u/s 68 - The regular assessment and block assessment are both separate proceedings and even can run parallel - assessee has failed to substantiate that relevant accommodation entry transactions - we reject the contention of Learned Counsel of the assessee seeking telescoping of the addition with the income already assessed in the block assessment order. - AT
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TaxTMI 
TaxTMI 
of 4879 
