Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Diversion of income by an overriding title - the payment made to ex-partners or to the spouses of the deceased partners was not application of money - it was a case of diversion of income by an overriding title - No tax liability - AT
Diversion of income by an overriding title - the payment made to ex-partners or to the spouses of the deceased partners was not application of money - it was a case of diversion of income by an overriding title - No tax liability - AT
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