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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Addition on account of difference of the gross receipts shown in the 26AS in comparison to the ITR - Once the assessee has disputed the said amount pertaining to any of the bills raised by the assessee, then a proper enquiry ought to have been conducted by the AO to verify this fact. The assessee has expressed its inability to force the other party to rectify the TDS statement and consequently 26AS - we set aside this issue to the record of the AO for conducting a proper enquiry - AT
Addition on account of difference of the gross receipts shown in the 26AS in comparison to the ITR - Once the assessee has disputed the said amount pertaining to any of the bills raised by the assessee, then a proper enquiry ought to have been conducted by the AO to verify this fact. The assessee has expressed its inability to force the other party to rectify the TDS statement and consequently 26AS - we set aside this issue to the record of the AO for conducting a proper enquiry - AT
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