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...
Penalty u/s 271(1)(c) - Specific charge - There was obviously no clarity in the mind of the AO as to which limb of Section 271(1)(c) got attracted in the instant case for initiation, followed by imposition of penalty. ITAT was justified in law in deleting the penalty - HC
Penalty u/s 271(1)(c) - Specific charge - There was obviously no clarity in the mind of the AO as to which limb of Section 271(1)(c) got attracted in the instant case for initiation, followed by imposition of penalty. ITAT was justified in law in deleting the penalty - HC
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