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...
Accrual of income - Selection of year of assessment - the entire sum was received upfront in the year in question and TDS was also deducted on that basis - ITAT erred in concluding that the sum received in each of the AYs in question could be spread over five years on the basis of the subsequent agreements - HC
Accrual of income - Selection of year of assessment - the entire sum was received upfront in the year in question and TDS was also deducted on that basis - ITAT erred in concluding that the sum received in each of the AYs in question could be spread over five years on the basis of the subsequent agreements - HC
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