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...
Permanent Establishment – Chargeability of payments received u/s 9(1)(vii) r.w section 115A and 44DA of the Act - The taxpayer had a fixed place PE in India because RRIL’s premises were ‘available’ to all of employees and assessee paid all the expenses in maintaining its premises - AAR
Permanent Establishment – Chargeability of payments received u/s 9(1)(vii) r.w section 115A and 44DA of the Act - The taxpayer had a fixed place PE in India because RRIL’s premises were ‘available’ to all of employees and assessee paid all the expenses in maintaining its premises - AAR
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