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...
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Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
Revision u/s 263 - as per CIT AO has not examined increase in share capital - The Tribunal noted that the AO had indeed accepted the correct balance sheet filed during the assessment proceedings, and the discrepancies between the original and rectified balance sheets were duly explained by the assessee. Therefore, the assessment order was held to be neither erroneous nor prejudicial to the interests of revenue due to the thorough verification conducted by the AO.
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