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...
Revision u/s 263 - the disallowances under sections 14A and 36(1)(iii) of the Act were the "matters" before the CIT (Appeals) - the same does not come under the jurisdiction of the CIT u/s 263 - AT
Revision u/s 263 - the disallowances under sections 14A and 36(1)(iii) of the Act were the "matters" before the CIT (Appeals) - the same does not come under the jurisdiction of the CIT u/s 263 - AT
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