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...
Assessment mentioning the wrong PAN - PAN of the assessee was wrongly mentioned including the erroneous name in assessment order. The revenue authority was erred to make addition in the hand of the assessee which was not related at all to assessee. The deposit of cash in the bank is recorded in the books of accounts of M/s. Goni Book Shop Bhaderwah which is related to his father & uncle. The two assessments cannot be done under the same PAN. - AT
Assessment mentioning the wrong PAN - PAN of the assessee was wrongly mentioned including the erroneous name in assessment order. The revenue authority was erred to make addition in the hand of the assessee which was not related at all to assessee. The deposit of cash in the bank is recorded in the books of accounts of M/s. Goni Book Shop Bhaderwah which is related to his father & uncle. The two assessments cannot be done under the same PAN. - AT
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