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...
Computation of capital gain - Cost of acquisition - They brought the property to sale through Bank - The contention of the assessee was that the amount was paid directly to the loan account of the company with the bank. The assessee had not received any consideration and therefore there was no capital gain arising out of the above sale. However, the Assessing Officer rejected the contention of the assessee - Order of ITAT confirming the action of AO upheld - HC
Computation of capital gain - Cost of acquisition - They brought the property to sale through Bank - The contention of the assessee was that the amount was paid directly to the loan account of the company with the bank. The assessee had not received any consideration and therefore there was no capital gain arising out of the above sale. However, the Assessing Officer rejected the contention of the assessee - Order of ITAT confirming the action of AO upheld - HC
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