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...
Revision u/s 263 - allowability of sales promotion incentive which was admittedly not subjected to TDS under section 194H - We fail to understand how the AO has allowed the impugned expenditure without examining / verifying the agreement entered into between the assessee (the payer) and its dealers (the payees). - Revision proceedings sustained - AT
Revision u/s 263 - allowability of sales promotion incentive which was admittedly not subjected to TDS under section 194H - We fail to understand how the AO has allowed the impugned expenditure without examining / verifying the agreement entered into between the assessee (the payer) and its dealers (the payees). - Revision proceedings sustained - AT
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