Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TDS u/s 195 - the remittances made to GEISA towards use of Pro-E software or Global Web are not royalty income chargeable to tax under the Act as well as under the treaty and consequently the assessee cannot be treated as an ‘assessee-in-default’ under section 201 of the Act for non-deduction of taxes under section 195 - AT
TDS u/s 195 - the remittances made to GEISA towards use of Pro-E software or Global Web are not royalty income chargeable to tax under the Act as well as under the treaty and consequently the assessee cannot be treated as an ‘assessee-in-default’ under section 201 of the Act for non-deduction of taxes under section 195 - AT
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