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...
AO made the addition of commission expense paid to AEMS without confronting from assessee that no reply was received by him in response to the notice issued u/s 133(6) of the Act to AEMS - no addition can be made - AT
AO made the addition of commission expense paid to AEMS without confronting from assessee that no reply was received by him in response to the notice issued u/s 133(6) of the Act to AEMS - no addition can be made - AT
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