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...
Deemed dividend - Whether the receipt of share application money can be treated and recorded as loan, deposits and “any payment“ for invoking the provisions of section 2(22)(e) - Held no - HC
Deemed dividend - Whether the receipt of share application money can be treated and recorded as loan, deposits and “any payment“ for invoking the provisions of section 2(22)(e) - Held no - HC
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