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...
Validity of assessment Order framed on Non quoting the mandatory document identification number (‘DIN’) - AO communicated the DIN after the expiry of 15 days - AO communicated the DIN after the expiry of 15 days - the communication issued manually in such circumstances must also state the reasons why communication is issued manually without a DIN and must also mention the date and number of written approval of the Chief Commissioner/Director General of Income-tax for issuing manual communication. - Assessment order quashed - AT
Validity of assessment Order framed on Non quoting the mandatory document identification number (‘DIN’) - AO communicated the DIN after the expiry of 15 days - AO communicated the DIN after the expiry of 15 days - the communication issued manually in such circumstances must also state the reasons why communication is issued manually without a DIN and must also mention the date and number of written approval of the Chief Commissioner/Director General of Income-tax for issuing manual communication. - Assessment order quashed - AT
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