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...
Validity of notice under Section 201 - insofar as the Financial Year 2007-2008 is concerned, in the circumstances of this case, no order can be made under sub-Section (1) of Section 201 after 31.03.2011. Since the notice itself had been issued on 17.02.2014, it is clearly time barred. - HC
Validity of notice under Section 201 - insofar as the Financial Year 2007-2008 is concerned, in the circumstances of this case, no order can be made under sub-Section (1) of Section 201 after 31.03.2011. Since the notice itself had been issued on 17.02.2014, it is clearly time barred. - HC
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