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Product similarity is must for applying CUP method, not for TNMM.
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International Tax
Product similarity is must for applying CUP method, not for TNMM.
Posted on
on
June 25, 2013
Tenet Tax Daily June 25 2013
By
tenettax-team
International Tax
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Notice dispatched to assessee under section 143(2) after date fixed for hearing would tantamount to denial of reasonable opportunity of hearing to assessee and, in such case, the order passed by revenue authority was not sustainable as it violated the principles of natural justice
Merely assisting a non-resident principal would not cause an agent to be considered as PE