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...
Addition u/s. 41(1) - cessation of liability - assessee had continuously avoided the payment of tax by showing the said interest liability as payable, whereas the creditor AOP had not shown it as its ‘income’ because of the different accounting methods, that too, so managed by the assessee - additions confirmed - AT
Addition u/s. 41(1) - cessation of liability - assessee had continuously avoided the payment of tax by showing the said interest liability as payable, whereas the creditor AOP had not shown it as its ‘income’ because of the different accounting methods, that too, so managed by the assessee - additions confirmed - AT
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