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...
Disallowance of set off and carry forward of Long Term Capital Loss of sale of quoted equity shares (STT paid) against LTCG arising on sale of property - the income contemplated u/s 10(38) was only a part of the source of capital gains on shares and only a limited portion of source was treated as exempt and not the entire capital gains. - carry forward allowed.
Disallowance of set off and carry forward of Long Term Capital Loss of sale of quoted equity shares (STT paid) against LTCG arising on sale of property - the income contemplated u/s 10(38) was only a part of the source of capital gains on shares and only a limited portion of source was treated as exempt and not the entire capital gains. - carry forward allowed.
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