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...
Transfer u/s 2(47) - Exemption u/s 47(xiii) - partnership firm succeeded by a private limited company - Treating value of land as loan in hands of company amounts to an indirect transfer of property to the partners - exemption denied - AT
Transfer u/s 2(47) - Exemption u/s 47(xiii) - partnership firm succeeded by a private limited company - Treating value of land as loan in hands of company amounts to an indirect transfer of property to the partners - exemption denied - AT
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