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 - disallowance u/s 40(a)(i) - overriding effect of section 172 - freight paid to non-resident shipping companies - there is no warrant in applying the provisions in chapter XVII for collection and recovery of the tax and its deduction at source vide section 195 - AT
TDS u/s 195 - disallowance u/s 40(a)(i) - overriding effect of section 172 - freight paid to non-resident shipping companies - there is no warrant in applying the provisions in chapter XVII for collection and recovery of the tax and its deduction at source vide section 195 - AT
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