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...
Levy of additional income tax u/s 104(1) - no actual accounting profit - the assessee could not distribute the dividend to it's shareholders. - there is no question of applicability of Section 104 - HC
Levy of additional income tax u/s 104(1) - no actual accounting profit - the assessee could not distribute the dividend to it's shareholders. - there is no question of applicability of Section 104 - HC
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