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...
STCG - extinguishment would normally connote a situation where an asset goes out of existence – thus, surplus arising on account of compensation received by the assessee cannot be assessed under the head “capital gain“ because no asset came into existence with the assessee. - AT
STCG - extinguishment would normally connote a situation where an asset goes out of existence – thus, surplus arising on account of compensation received by the assessee cannot be assessed under the head “capital gain“ because no asset came into existence with the assessee. - AT
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