Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
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