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...
Income taxable in India - subscription revenue for allowed ‘access’ to the database to view the videos - taxability of foreign income in India - the subscription revenue received by the assessee is not taxable as ‘Royalty’ in the hands of the assessee under Article 12 of the India-USA DTAA - AT
Income taxable in India - subscription revenue for allowed ‘access’ to the database to view the videos - taxability of foreign income in India - the subscription revenue received by the assessee is not taxable as ‘Royalty’ in the hands of the assessee under Article 12 of the India-USA DTAA - AT
Note: It is a system-generated summary and is for quick reference only.