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...
Scrutiny assessment - Instructions issued by CBDT not complied with - Since, in the present case, the question of jurisdiction was to be decided first by the Assessing Officer, which has not been done, the assessment order was quashed being against the instructions of the CBDT - Order of ITAT quashing the order sustained - HC
Scrutiny assessment - Instructions issued by CBDT not complied with - Since, in the present case, the question of jurisdiction was to be decided first by the Assessing Officer, which has not been done, the assessment order was quashed being against the instructions of the CBDT - Order of ITAT quashing the order sustained - HC
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