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 towards foreign travel - expenditure as wholly and exclusively for the business - Bonafides and genuineness of the expenses incurred by the assessee towards foreign travel was never in doubt before the assessing officer or before the CIT-A or before the Tribunal, thus, we have no hesitation to hold that the disallowance done by the CIT-A, as affirmed by the Tribunal, is erroneous. - HC
Disallowance towards foreign travel - expenditure as wholly and exclusively for the business - Bonafides and genuineness of the expenses incurred by the assessee towards foreign travel was never in doubt before the assessing officer or before the CIT-A or before the Tribunal, thus, we have no hesitation to hold that the disallowance done by the CIT-A, as affirmed by the Tribunal, is erroneous. - HC
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