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 u/s 2(22)(e) - beneficial owner of 30% - The plea of the assessee that no direct payment was made by the company to the assessee has no relevance as the case of the assessee falls within the third limb i.e. payment on behalf or for the individual benefit of the shareholder.... - AT
Deemed dividend u/s 2(22)(e) - beneficial owner of 30% - The plea of the assessee that no direct payment was made by the company to the assessee has no relevance as the case of the assessee falls within the third limb i.e. payment on behalf or for the individual benefit of the shareholder.... - AT
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