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...
Levying interest u/s 234C - Advance tax - Non-deduction of TDS by the payer - The interest income received by the assessee from IOCL was liable for deduction of tax at source, which however, was not done by the payer. Accordingly, tax deductible at source on the aforesaid amount of interest income - This amount had to be excluded from the tax due on the returned income for the purpose of computing the interest liability u/s 234C - AT
Levying interest u/s 234C - Advance tax - Non-deduction of TDS by the payer - The interest income received by the assessee from IOCL was liable for deduction of tax at source, which however, was not done by the payer. Accordingly, tax deductible at source on the aforesaid amount of interest income - This amount had to be excluded from the tax due on the returned income for the purpose of computing the interest liability u/s 234C - AT
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