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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
Income taxable/attribuable in India - attributed 15% of the assessee’s income to India - applicability of the Galileo rule[2009 (2) TMI 497 - DELHI HIGH COURT] - Galileo Nederland BV [supra] has now merged with the order of this Court in Travelport [2023 (5) TMI 227 - SUPREME COURT] filed by the Revenue before this Court. - Revenue appeal dismissed - SC
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