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 40A(3) - the finding of fact has been recorded by two revenue authorities that the payments made by the assessee on a single day did not exceed ₹ 20,000/- to a person - no disallowance u/s 40A(3) - no substantial question of law arises
Addition u/s 40A(3) - the finding of fact has been recorded by two revenue authorities that the payments made by the assessee on a single day did not exceed ₹ 20,000/- to a person - no disallowance u/s 40A(3) - no substantial question of law arises
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