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...
Gains arising on buy-back of shares taxable u/s 46A or under section 45 - “Transfer” in section 46A - section 45 and section 46A operate in different fields. Section 45 covers actual capital gain on transfer of a capital asset but section 46A is about Deemed Capital gains on buy back of shares - section 46A is applicable in the present case.
Gains arising on buy-back of shares taxable u/s 46A or under section 45 - “Transfer” in section 46A - section 45 and section 46A operate in different fields. Section 45 covers actual capital gain on transfer of a capital asset but section 46A is about Deemed Capital gains on buy back of shares - section 46A is applicable in the present case.
Note: It is a system-generated summary and is for quick reference only.