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...
Disallowance u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
Disallowance u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
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