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 56(2)(vii)(b) - additional income - assessee has suo motu declared this amount post survey proceedings u/s 133A on the assessee - the addition under section 56(2)(vii)(b) has to be adjusted and telescoped out of this suo motu voluntary disclosure of the assessee - AT
Addition u/s 56(2)(vii)(b) - additional income - assessee has suo motu declared this amount post survey proceedings u/s 133A on the assessee - the addition under section 56(2)(vii)(b) has to be adjusted and telescoped out of this suo motu voluntary disclosure of the assessee - AT
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