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...
Deduction u/s 80IB - undertaking not qualifying as an SSI (Small Scale Industry) unit - Considering our finding above of inclusion of computers cost, patterns, fixtures and factory equipment and product development and preoperative cost, this alone makes the assessee ineligible to SSI status as per IDRA Act and it can be safely held accordingly therefore that the assessee is not eligible to deduction u/s 80IB of the Act. - AT
Deduction u/s 80IB - undertaking not qualifying as an SSI (Small Scale Industry) unit - Considering our finding above of inclusion of computers cost, patterns, fixtures and factory equipment and product development and preoperative cost, this alone makes the assessee ineligible to SSI status as per IDRA Act and it can be safely held accordingly therefore that the assessee is not eligible to deduction u/s 80IB of the Act. - AT
Note: It is a system-generated summary and is for quick reference only.