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...
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
Note: It is a system-generated summary and is for quick reference only.
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