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...
TDS u/s 193 - Non-deduction of TDS on the interest expenses incurred on deep discount bonds - If the assessee is not incurring any expense, the question of income in the hands of the payee does not arise. Accordingly, the provisions for deducting the TDS as provided under “Chapter XVII, B- Deduction at source” of the Act will not be attracted. - AT
TDS u/s 193 - Non-deduction of TDS on the interest expenses incurred on deep discount bonds - If the assessee is not incurring any expense, the question of income in the hands of the payee does not arise. Accordingly, the provisions for deducting the TDS as provided under “Chapter XVII, B- Deduction at source” of the Act will not be attracted. - AT
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