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...
Addition u/s 68 - assessee has received unsecured loan - as per AO lenders are not capable of providing such loan to assessee - Identity was not disputed by the AO. - The entire transactions took place through banking channel, therefore no justification for making such addition. - AT
Addition u/s 68 - assessee has received unsecured loan - as per AO lenders are not capable of providing such loan to assessee - Identity was not disputed by the AO. - The entire transactions took place through banking channel, therefore no justification for making such addition. - AT
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