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 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
Revision u/s 263 - estimation of income on bogus purchases - Keeping in view the applicable VAT rate, Ld. AO estimated a further addition of 1.6% against these purchases. - Merely because Ld. Pr. CIT held a view that the estimation should have been at higher rates or entire purchase should have been disallowed, the same would not make the order erroneous - AT
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