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 on account of rolling charges received outside the books of account - In the absence of any material being brought on record by the appellant to explain that the expenditure shown to have been incurred by it as per the entries made in the seized document, was recorded in the books of account, no fault can be found in the order passed by the Tribunal restoring addition of amount - HC
Addition on account of rolling charges received outside the books of account - In the absence of any material being brought on record by the appellant to explain that the expenditure shown to have been incurred by it as per the entries made in the seized document, was recorded in the books of account, no fault can be found in the order passed by the Tribunal restoring addition of amount - HC
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