Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Income deemed to accrue or arise in India - existence or otherwise of a Permanent Establishment (PE) in India - In fact, even at the stage of Tribunal, no contrary material has been brought on record by the Revenue to rebut the claim of the assessee that no PE existed in these years. - No profit shall be attributable - AT
Income deemed to accrue or arise in India - existence or otherwise of a Permanent Establishment (PE) in India - In fact, even at the stage of Tribunal, no contrary material has been brought on record by the Revenue to rebut the claim of the assessee that no PE existed in these years. - No profit shall be attributable - AT
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