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...
Entitlement to exemption u/s 10(23C)(iv) r.w.s. 2(15) - assessee itself has entertained doubts about its exemption and filed a revised return, which itself shows that the assessee was not eligible for exemption - assessee is not entitled for exemption, therefore, the principle of consistency cannot be followed - AT
Entitlement to exemption u/s 10(23C)(iv) r.w.s. 2(15) - assessee itself has entertained doubts about its exemption and filed a revised return, which itself shows that the assessee was not eligible for exemption - assessee is not entitled for exemption, therefore, the principle of consistency cannot be followed - AT
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