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...
Nature of Lease rents paid - there was no real distinction between mischief of such a transfer in perpetuity and a transfer for the long period of 96 years - a permanent lease is as much an alienation as a sale - expenditure is of capital in nature - HC
Nature of Lease rents paid - there was no real distinction between mischief of such a transfer in perpetuity and a transfer for the long period of 96 years - a permanent lease is as much an alienation as a sale - expenditure is of capital in nature - HC
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