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...
Taxability on the Settlement Amount payable under the Stipulation pursuant to the judgment and Final approval of the US Court - applicant is required to deduct income-tax @ 30% when the settlement amount moves from the segregated account to the initial escrow account. - AAR
Taxability on the Settlement Amount payable under the Stipulation pursuant to the judgment and Final approval of the US Court - applicant is required to deduct income-tax @ 30% when the settlement amount moves from the segregated account to the initial escrow account. - AAR
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