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...
TP Adjustment - ‘receipt of counter guarantee commission - providing counter guarantee at the instance of its overseas AE - TPA made in the impugned assessment order towards counter guarantee commission is thus grossly at odds with the factual position enunciated by the co-ordinate benches and hence such adjustment is totally uncalled for. - AT
TP Adjustment - ‘receipt of counter guarantee commission - providing counter guarantee at the instance of its overseas AE - TPA made in the impugned assessment order towards counter guarantee commission is thus grossly at odds with the factual position enunciated by the co-ordinate benches and hence such adjustment is totally uncalled for. - AT
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