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...
Addition u/s 68 - the deposit in HSBC London - the assessee has not been able to provide any cogent evidence for the source of deposits. The submissions of the assessee have been without any reliable material. The explanation given by the assessee is only self-serving and has correctly been rejected by the lower authorities. - AT
Addition u/s 68 - the deposit in HSBC London - the assessee has not been able to provide any cogent evidence for the source of deposits. The submissions of the assessee have been without any reliable material. The explanation given by the assessee is only self-serving and has correctly been rejected by the lower authorities. - AT
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