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 Appellate Tribunal addressed various issues: (1) Discrepancy in income due to different accounting methods for fees, service tax, and GST. Assessee's reconciliation supported by explanations and evidence accepted, and addition by AO deleted. (2) Payment to retired partners as per partnership deed for incomplete work justified; addition deleted. (3) Short credit of TDS to be verified as directed by CIT(A), remitted back to AO for verification. Assessee's grounds allowed on all issues.
The Appellate Tribunal addressed various issues: (1) Discrepancy in income due to different accounting methods for fees, service tax, and GST. Assessee's reconciliation supported by explanations and evidence accepted, and addition by AO deleted. (2) Payment to retired partners as per partnership deed for incomplete work justified; addition deleted. (3) Short credit of TDS to be verified as directed by CIT(A), remitted back to AO for verification. Assessee's grounds allowed on all issues.
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