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...
Supply of services - local services or export of services - services provided to the US Client directly - benefit of zero-rated - The statute is unambiguous in as much as it says, the person liable to pay the consideration for supply of services is the ‘Recipient’ of such supply and ‘Consideration’ is any payment made whether by the recipient or any other person for such supply. - Order of AAR sustained - AAAR
Supply of services - local services or export of services - services provided to the US Client directly - benefit of zero-rated - The statute is unambiguous in as much as it says, the person liable to pay the consideration for supply of services is the ‘Recipient’ of such supply and ‘Consideration’ is any payment made whether by the recipient or any other person for such supply. - Order of AAR sustained - AAAR
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