Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Objective characteristics govern magnesium bis-glycinate chelate classification as an amino-acid coordination compound, not a food preparation or anti...
Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and supervision charges - Assessing officer could not bring any material on record which would establish such a relationship between the independent parties and non-resident vendors wherein habitual/sustained ability to negotiate or secure contracts could be demonstrated. The ld. assessing officer has jumped to the conclusion of existence of permanent establishment due to the involvement of local parties providing auxiliary services. - AT
TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and supervision charges - Assessing officer could not bring any material on record which would establish such a relationship between the independent parties and non-resident vendors wherein habitual/sustained ability to negotiate or secure contracts could be demonstrated. The ld. assessing officer has jumped to the conclusion of existence of permanent establishment due to the involvement of local parties providing auxiliary services. - AT
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