Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Penalty under section 271G of the Income tax Act – TPA - failure to furnish information and documents required by an Assessing Officer under Section 92D - The documentation or information should be one specified in Rule 10D - no penalty - HC
Penalty under section 271G of the Income tax Act – TPA - failure to furnish information and documents required by an Assessing Officer under Section 92D - The documentation or information should be one specified in Rule 10D - no penalty - HC
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