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...
Exercising power of AO by the Addl. CIT - Validity of framing of assessment by the ld. Additional Commissioner of Income Tax - in absence of a valid notification under section 120(4)(b) the Addl. CIT cannot exercise power of an Assessing Officer. - AT
Exercising power of AO by the Addl. CIT - Validity of framing of assessment by the ld. Additional Commissioner of Income Tax - in absence of a valid notification under section 120(4)(b) the Addl. CIT cannot exercise power of an Assessing Officer. - AT
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