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...
Disallowance of Expenses - assessee did not actually provide any professional services at all, but six persons who were employees of the assessee on paper but actually work for the parent company - Disallowance confirmed - AT
Disallowance of Expenses - assessee did not actually provide any professional services at all, but six persons who were employees of the assessee on paper but actually work for the parent company - Disallowance confirmed - AT
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