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...
Accrual of interest - assessee has not received any amount till date. - No benefit has been received, so no addition can be made on the notional income. However, the department is always at liberty to charge tax as and when the amount will be received by the assessee - HC
Accrual of interest - assessee has not received any amount till date. - No benefit has been received, so no addition can be made on the notional income. However, the department is always at liberty to charge tax as and when the amount will be received by the assessee - HC
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