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 - Disallowance u/s 14A r.w.r. 8D - There is no reference in the assessment order that these investments did not earn any exempt income nor assessee has filed details before the assessing officer. Therefore, assessment order passed by the assessing officer is erroneous and prejudicial to the interest of Revenue. - AT
Revision u/s 263 - Disallowance u/s 14A r.w.r. 8D - There is no reference in the assessment order that these investments did not earn any exempt income nor assessee has filed details before the assessing officer. Therefore, assessment order passed by the assessing officer is erroneous and prejudicial to the interest of Revenue. - AT
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