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...
TP Adjustment - application for early hearing and stay application was rejected by the ITAT - Matter restored before the ITAT - Till then, no coercive steps be taken against the appellant, for recovery of the tax demand.
TP Adjustment - application for early hearing and stay application was rejected by the ITAT - Matter restored before the ITAT - Till then, no coercive steps be taken against the appellant, for recovery of the tax demand.
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