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...
Penalty imposed u/s. 271B - non filing of audit report within stipulated time - the assessee kept on changing its version for causing delay of filing tax audit report and without any evidence substantiating the said reasons. Having perused the entire record and find no valid reasons supporting the reasons stated by the assessee for delay in filing tax audit report - Levy of penalty confirmed- AT
Penalty imposed u/s. 271B - non filing of audit report within stipulated time - the assessee kept on changing its version for causing delay of filing tax audit report and without any evidence substantiating the said reasons. Having perused the entire record and find no valid reasons supporting the reasons stated by the assessee for delay in filing tax audit report - Levy of penalty confirmed- AT
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