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...
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
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