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...
Computation of LTCG - Based on a reading of Section 50CA of the Act, it is clear that where the actual sale consideration on transfer of unlisted equity shares is less than the fair market value of such shares determined as per the NAV method, the actual sales consideration shall get substituted with the deemed sales consideration as determined in accordance with NAV method. - the Assessee had sold shares in excess of fair market value as determined in accordance with Rule 11UAA of the Rules. - here is no need to tinker with the full value of consideration declared by the assessee. - AT
Computation of LTCG - Based on a reading of Section 50CA of the Act, it is clear that where the actual sale consideration on transfer of unlisted equity shares is less than the fair market value of such shares determined as per the NAV method, the actual sales consideration shall get substituted with the deemed sales consideration as determined in accordance with NAV method. - the Assessee had sold shares in excess of fair market value as determined in accordance with Rule 11UAA of the Rules. - here is no need to tinker with the full value of consideration declared by the assessee. - AT
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