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 37(1) - sponsorship expenses - business promotional activities - it was not open for Ld. AO to question the commercial wisdom of the assessee as to how the business was to be promoted. - Assessee’s logo has been used on stationary items and other record books which would be used by large number of students and enhance the image of the assessee in the minds of the parents of the students. - 100% of the claim allowed - AT
Disallowance u/s 37(1) - sponsorship expenses - business promotional activities - it was not open for Ld. AO to question the commercial wisdom of the assessee as to how the business was to be promoted. - Assessee’s logo has been used on stationary items and other record books which would be used by large number of students and enhance the image of the assessee in the minds of the parents of the students. - 100% of the claim allowed - AT
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