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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Undisclosed profit and unaccounted investment in undervalued goods - It was observed by the Tribunal that when the very basis on which the addition was made by the Assessing Officer stands deleted by the CESTAT in appeal preferred by the assessee, the addition based on their information does not survive and hence, the CIT(Appeals) has rightly deleted the addition on account of unaccounted investment and Gross profit. No substantial question of law. - HC
Undisclosed profit and unaccounted investment in undervalued goods - It was observed by the Tribunal that when the very basis on which the addition was made by the Assessing Officer stands deleted by the CESTAT in appeal preferred by the assessee, the addition based on their information does not survive and hence, the CIT(Appeals) has rightly deleted the addition on account of unaccounted investment and Gross profit. No substantial question of law. - HC
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