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 - received to restrain the assessee firstly, preventing them from entering into insurance business, secondly, preventing them from entering into an agreement with any other foreign insurance company - the condition is clear and lucid and it is to be treated as a 'restrictive covenant' - amount received was a capital receipt
Characterization of income - received to restrain the assessee firstly, preventing them from entering into insurance business, secondly, preventing them from entering into an agreement with any other foreign insurance company - the condition is clear and lucid and it is to be treated as a 'restrictive covenant' - amount received was a capital receipt
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