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...
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
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