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...
Maintainability of deduction u/s. 80-IA on ‘Clean Development Mechanism’ (CDM) receipt by the assessee in respect of it’s two power generating units - true, the CERs, though intangible, are to be valued as inventories, but it is only on account of the protocol that they stand to be recognized separately and are valuable/realizable - Deduction not allowed - AT
Maintainability of deduction u/s. 80-IA on ‘Clean Development Mechanism’ (CDM) receipt by the assessee in respect of it’s two power generating units - true, the CERs, though intangible, are to be valued as inventories, but it is only on account of the protocol that they stand to be recognized separately and are valuable/realizable - Deduction not allowed - AT
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