Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Attributing income to the PE, under the DTAA - The income to the foreign branch from the credit given to its card holders outside India cannot be taxed in the hands of the Indian branch since it has not arisen in India and also it cannot be attributed to the assets and activities of the Indian branch, as is required by Article 7 of the DTAA. - AT
Attributing income to the PE, under the DTAA - The income to the foreign branch from the credit given to its card holders outside India cannot be taxed in the hands of the Indian branch since it has not arisen in India and also it cannot be attributed to the assets and activities of the Indian branch, as is required by Article 7 of the DTAA. - AT
Note: It is a system-generated summary and is for quick reference only.