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...
Under-valuation being from related persons - interconnected undertaking - Both the entities are controlled by the same person - All the observations are fact based observations. - demand confirmed invoking extended period of limitation - AT
Under-valuation being from related persons - interconnected undertaking - Both the entities are controlled by the same person - All the observations are fact based observations. - demand confirmed invoking extended period of limitation - AT
Note: It is a system-generated summary and is for quick reference only.