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 40(b)(v) - deduction of the amount of remuneration paid to the partners - the appellant has to be authorized by the partnership deed and the same has to be in accordance with the terms of the partnership deed. Referring to the partnership deed constituting the appellant, Tribunal held that the partnership deed did not contain any terms for payment to the working partners. - Additions made by ITAT confirmed - HC
Deduction u/s 40(b)(v) - deduction of the amount of remuneration paid to the partners - the appellant has to be authorized by the partnership deed and the same has to be in accordance with the terms of the partnership deed. Referring to the partnership deed constituting the appellant, Tribunal held that the partnership deed did not contain any terms for payment to the working partners. - Additions made by ITAT confirmed - HC
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