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...
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
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