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...
Disallowance of the expenses claimed on ad hoc basis - If the AO was of the view that some of the vouchers are missing, the amount of addition should have been made of the same amount. Merely due to smallness of amount cannot result into any disallowance. We do not find any infirmity in the order of the CIT (A) in deleting the disallowance out of the expenses. - AT
Disallowance of the expenses claimed on ad hoc basis - If the AO was of the view that some of the vouchers are missing, the amount of addition should have been made of the same amount. Merely due to smallness of amount cannot result into any disallowance. We do not find any infirmity in the order of the CIT (A) in deleting the disallowance out of the expenses. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
