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 of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
Disallowance of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
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