Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
TP Adjustment - Interest on External Commercial Borrowing (ECB) - The Tribunal found that the term of the ECB loan was indeed five years, not four years as asserted by the Revenue authorities. Considering past acceptance of similar interest rates by the TPO, the Tribunal ruled in favor of the assessee, allowing the interest payment on ECBs at the claimed rate.
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TaxTMI 
TaxTMI 
of 4881 
