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...
Disallowance of commission paid to Managing Director and Working Director - it cannot be doubted that the payment of dividend was made in the guise of commission to the directors.
Disallowance of commission paid to Managing Director and Working Director - it cannot be doubted that the payment of dividend was made in the guise of commission to the directors.
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