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...
Prosecution proceedings for TDS default - allegation that petitioner’s firm had deducted TDS for the financial year 2015-16, Assessment year 2016-17 but failed to deposit the same with the department - on deposit of TDS with interest, penalty was waived - there was no occasion to proceed against the petitioner under section 276(B) of the Income Tax Act. - HC
Prosecution proceedings for TDS default - allegation that petitioner’s firm had deducted TDS for the financial year 2015-16, Assessment year 2016-17 but failed to deposit the same with the department - on deposit of TDS with interest, penalty was waived - there was no occasion to proceed against the petitioner under section 276(B) of the Income Tax Act. - HC
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