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...
Protective addition cannot be converted into substantive addition in the hands of an assessee merely because substantive addition was not made in the hands of another assessee. - AT
Protective addition cannot be converted into substantive addition in the hands of an assessee merely because substantive addition was not made in the hands of another assessee. - AT
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