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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Estimation of income - Bogus purchases - The doubt, if any, is only with regard to the source of purchases. In such circumstances, the entire purchases cannot disallowed. As rightly observed by Commissioner (Appeals), only the profit element embedded in such purchases can be considered for disallowance. - disallowance @ 12.5% of the alleged non–genuine purchases is fair and reasonable - AT
Estimation of income - Bogus purchases - The doubt, if any, is only with regard to the source of purchases. In such circumstances, the entire purchases cannot disallowed. As rightly observed by Commissioner (Appeals), only the profit element embedded in such purchases can be considered for disallowance. - disallowance @ 12.5% of the alleged non–genuine purchases is fair and reasonable - AT
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