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...
Set-off of the losses against the deemed income u/s 69C - Determination of correct head of income - there is no iota of doubt that the deemed income assessed u/s 69C of the Act should not be treated as income falling outside the ambit of classification contained in section 14. - Therefore lower authorities committed illegality in not allowing the set-off of the losses against the deemed income u/s 69C - AT
Set-off of the losses against the deemed income u/s 69C - Determination of correct head of income - there is no iota of doubt that the deemed income assessed u/s 69C of the Act should not be treated as income falling outside the ambit of classification contained in section 14. - Therefore lower authorities committed illegality in not allowing the set-off of the losses against the deemed income u/s 69C - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
