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...
Revision u/s 263 - period of limitation - To be calculated from the date of original assessment or from the date of re-assessment after reopening - the issue on which the ld. PCIT proposed the revision of order framed u/s 144 r.w.s. 147 dated 29.09.2021, in which these two scrips were not the subject matter of re-assessment proceedings. Therefore, the period of limitation has to run from the date of assessment as framed under section 143(1) dated 18.06.2013 - AT
Revision u/s 263 - period of limitation - To be calculated from the date of original assessment or from the date of re-assessment after reopening - the issue on which the ld. PCIT proposed the revision of order framed u/s 144 r.w.s. 147 dated 29.09.2021, in which these two scrips were not the subject matter of re-assessment proceedings. Therefore, the period of limitation has to run from the date of assessment as framed under section 143(1) dated 18.06.2013 - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
