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 194C OR 194J - payee recipient had to merely issue its intellectual/technical skills without any physical work through employee or deploy assets - its recipient’s information technology related integrated service activities amount to technical services only. The assessee’s reliance on its itemized billings of the above services in classifying the same as bundled payments/services cannot be accepted - AT
TDS u/s 194C OR 194J - payee recipient had to merely issue its intellectual/technical skills without any physical work through employee or deploy assets - its recipient’s information technology related integrated service activities amount to technical services only. The assessee’s reliance on its itemized billings of the above services in classifying the same as bundled payments/services cannot be accepted - AT
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