Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Income accrued in India - Rendering services to non-resident entities - Though, the assessing officer has generally observed that in course of providing services to the assessee, the non-resident entities have made available technical knowledge, know-how, processes to the assessee. However, no substantive material has been brought on record by him to back such conclusion. - it is very much clear, the conditions of Article 12(4) of the tax treaty are not fulfilled. - AT
Income accrued in India - Rendering services to non-resident entities - Though, the assessing officer has generally observed that in course of providing services to the assessee, the non-resident entities have made available technical knowledge, know-how, processes to the assessee. However, no substantive material has been brought on record by him to back such conclusion. - it is very much clear, the conditions of Article 12(4) of the tax treaty are not fulfilled. - AT
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