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...
Penalty u/s 272A(2)(c) - interest payment exceeding ₹ 10,000 - non deduction of TDS u/s 194A - Other than filing appeals and not representing the same, nor giving explanation in respect of the grounds raised only delay tactics are being adopted. No reasonable cause has also been shown. - such contumacious conduct on the part of the assessee is liable to be dealt with harshly - AT
Penalty u/s 272A(2)(c) - interest payment exceeding ₹ 10,000 - non deduction of TDS u/s 194A - Other than filing appeals and not representing the same, nor giving explanation in respect of the grounds raised only delay tactics are being adopted. No reasonable cause has also been shown. - such contumacious conduct on the part of the assessee is liable to be dealt with harshly - AT
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