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...
Accrual of income in India u/s 5(2) - Foreign allowances on account of the international assignment - assessee was an employee in IBM India Private Limited and during the financial year 2012-13 was sent on short term assignment to Switzerland. - exemption in respect of foreign assignment allowance allowed.
Accrual of income in India u/s 5(2) - Foreign allowances on account of the international assignment - assessee was an employee in IBM India Private Limited and during the financial year 2012-13 was sent on short term assignment to Switzerland. - exemption in respect of foreign assignment allowance allowed.
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