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 by invoking the provisions of Section 56(2)(viia) which is applicable from 01/06/2010 - nothing is brought on record to substantiate that the shares were transferred in the month of November 2010, on the contrary the annual return filed by the Seller of the shares clearly established that the transfer of the shares took place on 10/05/2010 - no addition
Addition by invoking the provisions of Section 56(2)(viia) which is applicable from 01/06/2010 - nothing is brought on record to substantiate that the shares were transferred in the month of November 2010, on the contrary the annual return filed by the Seller of the shares clearly established that the transfer of the shares took place on 10/05/2010 - no addition
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