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...
Revisional jurisdiction under Section 20(1) - After six years from the date of order of assessment - revision order is wholly without jurisdiction and barred by limitation - HC
Revisional jurisdiction under Section 20(1) - After six years from the date of order of assessment - revision order is wholly without jurisdiction and barred by limitation - HC
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