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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
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