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...
Assessment u/s 153A - period of limitation - Section 153A was introduced in the Act notwithstanding the provisions, inter alia, of Sections 147 and Section 148. Hence, when no proceedings were taken under Section 153A, after the requisition made u/s 132, the Assessing Authority is disabled from proceeding for any assessment. - HC
Assessment u/s 153A - period of limitation - Section 153A was introduced in the Act notwithstanding the provisions, inter alia, of Sections 147 and Section 148. Hence, when no proceedings were taken under Section 153A, after the requisition made u/s 132, the Assessing Authority is disabled from proceeding for any assessment. - HC
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