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...
Restriction of disallowance - Bogus purchases - Restriction of disallowance @30% of total disallowance – addition of 12.5% net profit on bogus purchase is reasonable - AT
Restriction of disallowance - Bogus purchases - Restriction of disallowance @30% of total disallowance – addition of 12.5% net profit on bogus purchase is reasonable - AT
Note: It is a system-generated summary and is for quick reference only.