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...
Valuation - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
Valuation - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
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