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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
TDS u/s 192 or 195 - reimbursement of salary of employees seconded - The employees to whom the part salary were paid by Serco UK on behalf of the Assessee, have admittedly offered such salary amount as income by filling their Returns of Income in India and duly paid the income tax applicable and ITRs filled by said employees have also been accepted - by treating the salary amount as “FTS” provided, shall jeopardize the rights of Assessee and its employees - AT
TDS u/s 192 or 195 - reimbursement of salary of employees seconded - The employees to whom the part salary were paid by Serco UK on behalf of the Assessee, have admittedly offered such salary amount as income by filling their Returns of Income in India and duly paid the income tax applicable and ITRs filled by said employees have also been accepted - by treating the salary amount as “FTS” provided, shall jeopardize the rights of Assessee and its employees - AT
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