Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
This outsourcing of work to India would not give rise to a fixed place PE - Indian company only renders support services which enable the assessees in turn to render services to their clients abroad - SC
This outsourcing of work to India would not give rise to a fixed place PE - Indian company only renders support services which enable the assessees in turn to render services to their clients abroad - SC
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