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...
Penalty under section 271(1)(c) on addition of rental income - the assessment proceedings and penalty proceedings are quite distinct and the findings given in the assessment order are not conclusive. Accordingly, mere addition of amount as income is not the criteria to levy penalty. - AT
Penalty under section 271(1)(c) on addition of rental income - the assessment proceedings and penalty proceedings are quite distinct and the findings given in the assessment order are not conclusive. Accordingly, mere addition of amount as income is not the criteria to levy penalty. - AT
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