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...
Revision u/s 263 - Exemption claimed u/s 80 IB(11- C) - If certain assessment order was made by the Income Tax Officer the same could not be branded as erroneous by the Principal Commissioner of Income Tax merely because another view was possible - the Tribunal did not commit any error in holding that such enquiry was made by the Assessing Officer and hence there was no reason for the Pr. CIT to invoke jurisdiction u/s 263. - HC
Revision u/s 263 - Exemption claimed u/s 80 IB(11- C) - If certain assessment order was made by the Income Tax Officer the same could not be branded as erroneous by the Principal Commissioner of Income Tax merely because another view was possible - the Tribunal did not commit any error in holding that such enquiry was made by the Assessing Officer and hence there was no reason for the Pr. CIT to invoke jurisdiction u/s 263. - HC
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