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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
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