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...
Jurisdiction of CIT u/s 263 - revision - erroneous order - CIT wanted the AO to cause further enquiry and he had not stated what enquiry the AO has to do - revision is not proper - AT
Jurisdiction of CIT u/s 263 - revision - erroneous order - CIT wanted the AO to cause further enquiry and he had not stated what enquiry the AO has to do - revision is not proper - AT
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