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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT Bangalore ruled that the income received by the software company from software sales to IBM India and others did not constitute royalties under the applicable laws and treaties. This judgment aligns with SC's interpretation and emphasizes consistency in legal interpretations across different assessment years.
Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT Bangalore ruled that the income received by the software company from software sales to IBM India and others did not constitute royalties under the applicable laws and treaties. This judgment aligns with SC's interpretation and emphasizes consistency in legal interpretations across different assessment years.
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