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...
Accrual of income - addition on account of accrued interest on NPA account as income - the assessee had adequately established that the interest received during the year as pertained to interest of those years when the assessee was accounting for the interest on accrual basis - No additions - AT
Accrual of income - addition on account of accrued interest on NPA account as income - the assessee had adequately established that the interest received during the year as pertained to interest of those years when the assessee was accounting for the interest on accrual basis - No additions - AT
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