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...
Reopening of assessment - there was no negligence on the part of the assessee in furnishing the required details for completing the assessment. Thus reopening of the assessment beyond four years period from the end of the relevant assessment year is not justified - AT
Reopening of assessment - there was no negligence on the part of the assessee in furnishing the required details for completing the assessment. Thus reopening of the assessment beyond four years period from the end of the relevant assessment year is not justified - AT
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