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...
Deemed income u/s 41(1) - merely relying upon the expression ‘principal’ used in the letter, one cannot conclude that the amount contains only the principal component of loan, and no element of interest is embedded therein. - AT
Deemed income u/s 41(1) - merely relying upon the expression ‘principal’ used in the letter, one cannot conclude that the amount contains only the principal component of loan, and no element of interest is embedded therein. - AT
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