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...
TDS u/s 194H - Whether sale of recharge vouchers and prepaid vouchers and prepaid cards to the sole distributors does not establish Principal-Agent relationship liable to TDS under section 194H? - other High Court’s decisions are binding on the Tribunal to take a decision, but, since there exist two contradictory decisions other High Courts, if a statutory provision is capable of more than one view, then the view which favours the tax payer should be preferred.
TDS u/s 194H - Whether sale of recharge vouchers and prepaid vouchers and prepaid cards to the sole distributors does not establish Principal-Agent relationship liable to TDS under section 194H? - other High Court’s decisions are binding on the Tribunal to take a decision, but, since there exist two contradictory decisions other High Courts, if a statutory provision is capable of more than one view, then the view which favours the tax payer should be preferred.
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