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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Jurisdiction of Single Member Bench of the Income Tax Appellate Tribunal - Monetary limit Rs.50 lakhs for hearing Appeal - In the present case, the assessee returned loss of (-) Rs.1,05 crores. AO made addition of Rs.1,06 crores and finally he determined the income of (+) Rs. 40 thousands - Only assessed income has to be looked into as stipulated in sub-section (3) of section 255 of the Act - AT
Jurisdiction of Single Member Bench of the Income Tax Appellate Tribunal - Monetary limit Rs.50 lakhs for hearing Appeal - In the present case, the assessee returned loss of (-) Rs.1,05 crores. AO made addition of Rs.1,06 crores and finally he determined the income of (+) Rs. 40 thousands - Only assessed income has to be looked into as stipulated in sub-section (3) of section 255 of the Act - AT
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