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...
Once the amount is found to be incurred exclusively by H.O. towards the Indian branch, the same is required to be allowed in terms of section 37(1) without any reference to section 44C. - AT
Once the amount is found to be incurred exclusively by H.O. towards the Indian branch, the same is required to be allowed in terms of section 37(1) without any reference to section 44C. - AT
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