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...
Penalty u/s. 271F - The filing of return beyond the due date is admittedly invalid return as there is no provision for filing the return belatedly once notice u/s.153A has been issued. This being so, we are of the view that the assessee had a valid ground for non-filing of return. - No penalty - AT
Penalty u/s. 271F - The filing of return beyond the due date is admittedly invalid return as there is no provision for filing the return belatedly once notice u/s.153A has been issued. This being so, we are of the view that the assessee had a valid ground for non-filing of return. - No penalty - AT
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