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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Revision u/s 263 by CIT - AO has noted that details of expenses relating to business promotion, lease rent, commission, petrol, travelling etc. were filed by the assessee and which were checked. Therefore, in view of these facts and circumstances, we find that the Assessing Officer had carried out sufficient examination of the expenses relating to site & wages and therefore, passing of order u/s 263 on this account is also not justified. - AT
Revision u/s 263 by CIT - AO has noted that details of expenses relating to business promotion, lease rent, commission, petrol, travelling etc. were filed by the assessee and which were checked. Therefore, in view of these facts and circumstances, we find that the Assessing Officer had carried out sufficient examination of the expenses relating to site & wages and therefore, passing of order u/s 263 on this account is also not justified. - AT
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