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...
Disallowing set off of losses claimed by the appellant set-off of business losses and carried forward losses against the undisclosed income - We are of the view according to the CBDT Circular No. 11 of 2019 business losses and brought forward losses can be set-off against the income assessed under section 115BBE - AT
Disallowing set off of losses claimed by the appellant set-off of business losses and carried forward losses against the undisclosed income - We are of the view according to the CBDT Circular No. 11 of 2019 business losses and brought forward losses can be set-off against the income assessed under section 115BBE - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
