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...
Re-opening of assessments u/s 147 - beyond four years but within six years - There is no warrant to extend the period by two years, again as provided under Section 153, since on facts it cannot be said that the grant of exemption was in the absence of full and true disclosure by the assessee - HC
Re-opening of assessments u/s 147 - beyond four years but within six years - There is no warrant to extend the period by two years, again as provided under Section 153, since on facts it cannot be said that the grant of exemption was in the absence of full and true disclosure by the assessee - HC
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