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...
Deletion of penalty u/s 271D – Violation of provisions of Section 269SS or not –assessee was under the bona fide impression that the money received was only towards allotment of shares and it is not a loan or deposit - no penalty - HC
Deletion of penalty u/s 271D – Violation of provisions of Section 269SS or not –assessee was under the bona fide impression that the money received was only towards allotment of shares and it is not a loan or deposit - no penalty - HC
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