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...
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
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