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 as per Section 2(22)(e) - family arrangements - In the facts of the present case, the transaction between M/s.MEL and M/s.SREL being admittedly a business transaction, as is evident from the evidence on record, Section-2(22)(e) is not applicable.
Deemed dividend as per Section 2(22)(e) - family arrangements - In the facts of the present case, the transaction between M/s.MEL and M/s.SREL being admittedly a business transaction, as is evident from the evidence on record, Section-2(22)(e) is not applicable.
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