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...
TP Adjustment - specified domestic transaction of project management and supervision - Capitalized expenditure - AO is incorrect in determining the arm’s-length price of specified domestic transaction after omission of clause (i) of Section 92BA - the action of the learned transfer-pricing officer in determining the arm’s-length price of project management and supervision fees at Rs Nil and consequent disallowance of depreciation there on is not correct. - AT
TP Adjustment - specified domestic transaction of project management and supervision - Capitalized expenditure - AO is incorrect in determining the arm’s-length price of specified domestic transaction after omission of clause (i) of Section 92BA - the action of the learned transfer-pricing officer in determining the arm’s-length price of project management and supervision fees at Rs Nil and consequent disallowance of depreciation there on is not correct. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
