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...
Electronic upload of DRP directions on the ITBA module constitutes receipt of those directions in a faceless assessment. The final assessment must therefore be completed within the period prescribed under section 144C(13), calculated from that upload date. Where the final assessment is completed after the prescribed period, it is time-barred and liable to be set aside. Other assessment grounds remain open where invalidity is determined solely by limitation.
Electronic upload of DRP directions on the ITBA module constitutes receipt of those directions in a faceless assessment. The final assessment must therefore be completed within the period prescribed under section 144C(13), calculated from that upload date. Where the final assessment is completed after the prescribed period, it is time-barred and liable to be set aside. Other assessment grounds remain open where invalidity is determined solely by limitation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
