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...
Nature of expenditure - manufacturing and administrative expenses incurred by the appellant for development of a product in the course of its manufacturing activity which was already carried on - Same cannot be treated as revenue expenditure. - HC
Nature of expenditure - manufacturing and administrative expenses incurred by the appellant for development of a product in the course of its manufacturing activity which was already carried on - Same cannot be treated as revenue expenditure. - HC
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