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...
Allowable busniss expenses - Diversion of income - Though the amount has been received by the assessee, the same is collected on behalf of the joint venture - It is the settled law that the accounting entries are not determinative of the actual nature of the transaction; it is the substance that prevails. - AT
Allowable busniss expenses - Diversion of income - Though the amount has been received by the assessee, the same is collected on behalf of the joint venture - It is the settled law that the accounting entries are not determinative of the actual nature of the transaction; it is the substance that prevails. - AT
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