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 - simply because there were transactions of cheques received and cheques paid in the mutual, open, current, running account with the sister concerns, the same cannot be considered as payment by way of loans or advances so as to attract provisions of section 2(22)(e) - AT
Deemed dividend - simply because there were transactions of cheques received and cheques paid in the mutual, open, current, running account with the sister concerns, the same cannot be considered as payment by way of loans or advances so as to attract provisions of section 2(22)(e) - AT
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