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...
Re-opening of proceedings - Only revisional authority has power to seek re-opening of proceedings when Re-assessment order was prejudicial to the interest of revenue - HC
Re-opening of proceedings - Only revisional authority has power to seek re-opening of proceedings when Re-assessment order was prejudicial to the interest of revenue - HC
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