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...
Disallowance u/s 40A(3) - transactions and payments made in cash - assessee filed affidavits from sub-contractors of assessee firm and they insisted for cash payments to make payment to workers and confirmed the above payments - cash payments are made due to business expediency and being genuine transaction and the parties are identifiable, provisions of section 40A(3) cannot be applied - AT
Disallowance u/s 40A(3) - transactions and payments made in cash - assessee filed affidavits from sub-contractors of assessee firm and they insisted for cash payments to make payment to workers and confirmed the above payments - cash payments are made due to business expediency and being genuine transaction and the parties are identifiable, provisions of section 40A(3) cannot be applied - AT
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