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 - P.E. in India - The payments made by assessee to Gensler-USA were merely for project specific drawings & designs without transfer of technology or know-how or even title in drawing & designs - not in the nature of “Royalty” or “Fee for Technical Services”. - AT
TDS u/s 195 - P.E. in India - The payments made by assessee to Gensler-USA were merely for project specific drawings & designs without transfer of technology or know-how or even title in drawing & designs - not in the nature of “Royalty” or “Fee for Technical Services”. - AT
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