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...
Deduction u/s 80-IA - non-filing of Form 10CCB along with return of income - due to the technical glitches, Form 10CCB could not be uploaded on e-filing portal of the Income Tax Department - The reasons for non-filing of Form 10CCB along with return of income was on account of reasons beyond the control of the assessee and should not act as a bar to the allowability to the claim of deduction under section 80-IA. - AT
Deduction u/s 80-IA - non-filing of Form 10CCB along with return of income - due to the technical glitches, Form 10CCB could not be uploaded on e-filing portal of the Income Tax Department - The reasons for non-filing of Form 10CCB along with return of income was on account of reasons beyond the control of the assessee and should not act as a bar to the allowability to the claim of deduction under section 80-IA. - AT
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