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...
Assets leased out to various companies - Whether assets were in existence at the relevant time and whether the transactions in question were genuine or not - finding of fact - The aforesaid finding of fact has been affirmed by the Income Tax Appellate Tribunal. Thus, the matter stands concluded by concurrent findings of fact, which by no stretch of imagination can be said to be either based on no evidence or perverse. - Depreciation allowed - HC
Assets leased out to various companies - Whether assets were in existence at the relevant time and whether the transactions in question were genuine or not - finding of fact - The aforesaid finding of fact has been affirmed by the Income Tax Appellate Tribunal. Thus, the matter stands concluded by concurrent findings of fact, which by no stretch of imagination can be said to be either based on no evidence or perverse. - Depreciation allowed - HC
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