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...
Territorial jurisdiction of AO Kolkata - TDS liability - power to make the assessment - ITAT decided in favor of assessee, on ground of passage of time, without touching the basic issue of TDS liability of the assessee - Matter restored before the tribunal with direction.
Territorial jurisdiction of AO Kolkata - TDS liability - power to make the assessment - ITAT decided in favor of assessee, on ground of passage of time, without touching the basic issue of TDS liability of the assessee - Matter restored before the tribunal with direction.
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