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...
Foreign tax credits u/s 90/90A - Rule 128 is a procedural provision and not a mandatory provision - Rule 128 nowhere provides that if the said Form 67 is not filed within the above stated time frame, the relief as sought by the assessee u/s 90 of the Act would be denied. - AT
Foreign tax credits u/s 90/90A - Rule 128 is a procedural provision and not a mandatory provision - Rule 128 nowhere provides that if the said Form 67 is not filed within the above stated time frame, the relief as sought by the assessee u/s 90 of the Act would be denied. - AT
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