Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT
Income deemed to accrue or arise in India - royalty income - permanent establishment (PE) in India - Each project site did not exceed threshold limit of 183 days. - The project sites at Bangaluru and Gurugram cannot be considered to be either installation or supervisory PE of the assessee in India. - The assessee in the year under consideration did not have any PE in India. - AT
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