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...
Disallowance of foreign exchange loss – The provisions of section 43A of the Act could not apply to the facts of the case as the provisions can be invoked only when assets are acquired by raising the FCNR (B) loan - AT
Disallowance of foreign exchange loss – The provisions of section 43A of the Act could not apply to the facts of the case as the provisions can be invoked only when assets are acquired by raising the FCNR (B) loan - AT
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