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 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
Revision u/s 263 - unexplained cash credit u/s 68 - the documents were very much available on ‘record’ when the ld PCIT examined this assessment folder. When all these details were already on record, it is reasonably expected from ld PCIT to look into those details (as already forming part of record) before arriving at any conclusion that whether the said loan was squared up during the year or not. - PCIT had totally proceeded on incorrect assumption of fact - AT
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