Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
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Income deemed to accrue or arise in India - As undisputed factual position that ESPN India has been remunerated at arm’s length and there are no adjustments suggested by the TPO in any of the assessment years under dispute. That being the case, no further attribution of profit can be made to the PE. - the distribution revenue received by the assessee is not taxable in India. - AT
Income deemed to accrue or arise in India - As undisputed factual position that ESPN India has been remunerated at arm’s length and there are no adjustments suggested by the TPO in any of the assessment years under dispute. That being the case, no further attribution of profit can be made to the PE. - the distribution revenue received by the assessee is not taxable in India. - AT
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