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...
Mismatching of TDS receipts with P&L account - AO has considered the entire payment as per TDS certificate as income and has failed to appreciate what is liable is income, real profit and not payment received by the assessee. - AT
Mismatching of TDS receipts with P&L account - AO has considered the entire payment as per TDS certificate as income and has failed to appreciate what is liable is income, real profit and not payment received by the assessee. - AT
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