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...
Revision u/s 263 by CIT - when transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA(8) has been examined by the AO - revision order quashed.
Revision u/s 263 by CIT - when transfer price is consonance with the fair market price then conditions of this section gets satisfied. Hence applicability of section 80IA(8) has been examined by the AO - revision order quashed.
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