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...
Exemption u/s 11 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
Exemption u/s 11 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
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TaxTMI 
TaxTMI 
of 4886 
