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 - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.
TP adjustment - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.
Note: It is a system-generated summary and is for quick reference only.
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