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 - revenue had an efficacious remedy open to it in the form of a rectification u/s 154 for correcting a computational error and consequently recourse to the provisions of section 147 was not warranted - AT
Reopening of assessment - revenue had an efficacious remedy open to it in the form of a rectification u/s 154 for correcting a computational error and consequently recourse to the provisions of section 147 was not warranted - AT
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