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...
TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
TP adjustment - disallowance of interest - characterizing the share application money to associate enterprises as interest free advance - onus is upon the AO to prove that it is an international transaction of capital financing - Such a presumption cannot change the character of transaction
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