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 u/s.40(a)(ia) - Failure to deduct TDS - Scope of amendment - if a statute is curative of the previous law, retrospective operation is generally intended. - AO directed to restrict the 100% disallowance confirmed by the CIT(A) to the extent of 30% only taking into account the actual claim of the assessee in its profit and loss account. - AT
Disallowance u/s.40(a)(ia) - Failure to deduct TDS - Scope of amendment - if a statute is curative of the previous law, retrospective operation is generally intended. - AO directed to restrict the 100% disallowance confirmed by the CIT(A) to the extent of 30% only taking into account the actual claim of the assessee in its profit and loss account. - AT
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