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...
TDS u/s 195 - assessee purchased software from two nonresidents companies - Purchase of software is not in the nature of Royalty and no disallowance u/s.40(a)(i) of the Act is warranted. - AT
TDS u/s 195 - assessee purchased software from two nonresidents companies - Purchase of software is not in the nature of Royalty and no disallowance u/s.40(a)(i) of the Act is warranted. - AT
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