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...
Merger with the parent company - no capital gain chargeable to tax under the Act in terms of section 45 read with section 48 can be said to arise. - it cannot be postulated that section 47(via) takes the transaction out of the clutches of section 45 - The merger involved in this case, is not exempt from capital gains tax under section 47(via). - AAR
Merger with the parent company - no capital gain chargeable to tax under the Act in terms of section 45 read with section 48 can be said to arise. - it cannot be postulated that section 47(via) takes the transaction out of the clutches of section 45 - The merger involved in this case, is not exempt from capital gains tax under section 47(via). - AAR
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