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...
Conversion of limited scrutiny into complete scrutiny assessment - AO has not referred to any credible or reliable material or information to form the view that there was a possibility of under assessment of income in this case. The AO has merely made certain disallowance on ad hoc basis without pointing out any information or material available to him which has a direct nexus to show that there was possibility of under assessment of income. - Conversion of limited scrutiny into complete scrutiny is against the spirit of CBDT mandate which is binding on the AO. - AT
Conversion of limited scrutiny into complete scrutiny assessment - AO has not referred to any credible or reliable material or information to form the view that there was a possibility of under assessment of income in this case. The AO has merely made certain disallowance on ad hoc basis without pointing out any information or material available to him which has a direct nexus to show that there was possibility of under assessment of income. - Conversion of limited scrutiny into complete scrutiny is against the spirit of CBDT mandate which is binding on the AO. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
