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...
Reopening of assessment u/s 147 - reasons to believe - The Tribunal held that the reasons for reopening the assessment were vague and non-specific, and there was no failure on the part of the Assessee to fully disclose all material facts during the original assessment proceedings. Therefore, the initiation of reassessment proceedings was struck down.
Reopening of assessment u/s 147 - reasons to believe - The Tribunal held that the reasons for reopening the assessment were vague and non-specific, and there was no failure on the part of the Assessee to fully disclose all material facts during the original assessment proceedings. Therefore, the initiation of reassessment proceedings was struck down.
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