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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Set off of current year business loss against foreign dividend income - levy of tax u/s 115BBD on gross foreign dividend income - assessee would be entitled for set off of current year loss with the foreign dividend income, assessee would be entitled for set off of brought forward business losses and unabsorbed depreciation of earlier years with the foreign dividend income and assessee would be eligible for deduction u/s 80G of the Act from the Gross Total Income subject to the restrictions provided in that relevant section. - AT
Set off of current year business loss against foreign dividend income - levy of tax u/s 115BBD on gross foreign dividend income - assessee would be entitled for set off of current year loss with the foreign dividend income, assessee would be entitled for set off of brought forward business losses and unabsorbed depreciation of earlier years with the foreign dividend income and assessee would be eligible for deduction u/s 80G of the Act from the Gross Total Income subject to the restrictions provided in that relevant section. - AT
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