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...
Condonation of delay - delay in filing appeal - The assessee, has therefore, not been vigilant in challenging the re-assessment proceedings as well as the penalty proceedings. The assessee’s explanation is common for all the appeals proceedings. - Condonation of delay not allowed - AT
Condonation of delay - delay in filing appeal - The assessee, has therefore, not been vigilant in challenging the re-assessment proceedings as well as the penalty proceedings. The assessee’s explanation is common for all the appeals proceedings. - Condonation of delay not allowed - AT
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