Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
It is axiomatic that if the receipt is not taxable under the Income Tax Act, then there is no need to examine whether it would fall under any of the provisions of the agreement for avoidance of double taxation. - Decided against revenue. - HC
It is axiomatic that if the receipt is not taxable under the Income Tax Act, then there is no need to examine whether it would fall under any of the provisions of the agreement for avoidance of double taxation. - Decided against revenue. - HC
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