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...
Accrual of income - interest income earned on the fixed deposit - effect of overriding title - the Assessee never becomes the owner of money and as such the addition made by the AO was not sustainable in both the assessment years. - HC
Accrual of income - interest income earned on the fixed deposit - effect of overriding title - the Assessee never becomes the owner of money and as such the addition made by the AO was not sustainable in both the assessment years. - HC
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