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...
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Classification of services - pure services or not - Project Development Service - the Services rendered by the appellant to the State Urban Development Agency, Uttar Pradesh (SUDA), and for PMAY, are in relation to functions entrusted to Municipalities under Article 243W and to Panchayats under Article 243G of the Constitution of India and such services would qualify as Pure Service (excluding works contract service or other composite supplies involving supply of any goods). - AAR
Classification of services - pure services or not - Project Development Service - the Services rendered by the appellant to the State Urban Development Agency, Uttar Pradesh (SUDA), and for PMAY, are in relation to functions entrusted to Municipalities under Article 243W and to Panchayats under Article 243G of the Constitution of India and such services would qualify as Pure Service (excluding works contract service or other composite supplies involving supply of any goods). - AAR
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