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...
Profits in lieu of salary - chargeable to tax u/s 17(3) or section 28(va) - appellant was not an employee - compensation attributable to a negative/restrictive covenant is a capital receipt. - as the sum received by the appellant does not fall within the ambit of section 28(va), and being a capital receipt is not taxable - AT
Profits in lieu of salary - chargeable to tax u/s 17(3) or section 28(va) - appellant was not an employee - compensation attributable to a negative/restrictive covenant is a capital receipt. - as the sum received by the appellant does not fall within the ambit of section 28(va), and being a capital receipt is not taxable - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
