Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Income accrued in India - royalty receipts - what is sold is the copyrighted software which is shrink-wrapped - the consideration received on the sale of off-the-shelf, shrink-wrapped software to Indian distributors and resellers would not constitute royalty in terms of the India-UK Double Taxation Avoidance Agreement. - no substantial question of law arises - HC
Income accrued in India - royalty receipts - what is sold is the copyrighted software which is shrink-wrapped - the consideration received on the sale of off-the-shelf, shrink-wrapped software to Indian distributors and resellers would not constitute royalty in terms of the India-UK Double Taxation Avoidance Agreement. - no substantial question of law arises - HC
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