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...
Royalty payment to a related person - it is wrong to conclude that that Tarun Mohan being a Director of the respondent was not entitled to enter into an agreement for the transfer of his assets to the company - This ignores the fundamental concept that the assessee being a company incorporated under the Companies Act, 1956 is a separate legal juristic entity - HC
Royalty payment to a related person - it is wrong to conclude that that Tarun Mohan being a Director of the respondent was not entitled to enter into an agreement for the transfer of his assets to the company - This ignores the fundamental concept that the assessee being a company incorporated under the Companies Act, 1956 is a separate legal juristic entity - HC
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