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...
Denial of exchange loss - Unexpalined loss from the income - provisions of section 43A applicability - AS-11 is mandatory and required to be followed in computing the income - it cannot be held that neither depreciation on enhanced cost due to exchange fluctuation is to be allowed nor the loss itself was to be allowed more so because claim to this effect was raised both before the Assessing Officer as well as the CIT(A). - AT
Denial of exchange loss - Unexpalined loss from the income - provisions of section 43A applicability - AS-11 is mandatory and required to be followed in computing the income - it cannot be held that neither depreciation on enhanced cost due to exchange fluctuation is to be allowed nor the loss itself was to be allowed more so because claim to this effect was raised both before the Assessing Officer as well as the CIT(A). - AT
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