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...
Excess depreciation - cost of development of infrastructure facility of roads/highways - Action of the Ld. AO in applying the circular retrospectively is not in order. Accordingly, the disallowance made by the Ld. AO on account of difference between the depreciation claimed and the depreciation allowed on the basis of amortization for the remaining part of the concessionaire agreement is directed to be deleted - AT
Excess depreciation - cost of development of infrastructure facility of roads/highways - Action of the Ld. AO in applying the circular retrospectively is not in order. Accordingly, the disallowance made by the Ld. AO on account of difference between the depreciation claimed and the depreciation allowed on the basis of amortization for the remaining part of the concessionaire agreement is directed to be deleted - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
