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...
The Tribunal upheld the CIT(A)'s decision on various issues, dismissing the appeal of the Revenue. The implications include the affirmation of the deductibility of ESOP compensation, the restriction of disallowance under section 14A to investments yielding exempt income, the allowance of expenses related to the increase in authorized share capital, the recognition of legal and professional expenses as revenue expenditure, and the treatment of stale cheques as liabilities until settled or adjusted.
The Tribunal upheld the CIT(A)'s decision on various issues, dismissing the appeal of the Revenue. The implications include the affirmation of the deductibility of ESOP compensation, the restriction of disallowance under section 14A to investments yielding exempt income, the allowance of expenses related to the increase in authorized share capital, the recognition of legal and professional expenses as revenue expenditure, and the treatment of stale cheques as liabilities until settled or adjusted.
Note: It is a system-generated summary and is for quick reference only.