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...
Nature of expenses - expenses pertain to a film which may not be released - legal fees paid to the retainer advocates firm for taking care of litigation - Whether the film is released or not, or whether it turns out to be a dud project, as in this case, is wholly irrelevant. - Claim allowed - AT
Nature of expenses - expenses pertain to a film which may not be released - legal fees paid to the retainer advocates firm for taking care of litigation - Whether the film is released or not, or whether it turns out to be a dud project, as in this case, is wholly irrelevant. - Claim allowed - AT
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