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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Introduction of the authority of Joint Commissioner (Appeals) - In order to reduce burden or bottleneck of small cases with small amount of disputes and demand from commissioner of Appeals as it is first authority of appeal, it is proposed to be created at Joint Commissioner/ Additional Commissioner level. Such authority has all powers, responsibilities and accountability similar to that of Commissioner (Appeals) with respect to the procedure for disposal of appeals.
Introduction of the authority of Joint Commissioner (Appeals) - In order to reduce burden or bottleneck of small cases with small amount of disputes and demand from commissioner of Appeals as it is first authority of appeal, it is proposed to be created at Joint Commissioner/ Additional Commissioner level. Such authority has all powers, responsibilities and accountability similar to that of Commissioner (Appeals) with respect to the procedure for disposal of appeals.
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