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...
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
Low net profit ratio - AO has not pointed out any defect or deficiency in the claim of expenditure nor any expenditure has been held as bogus by the AO. AO asked financial results of the last three years and proceeded to make addition in this regard without confronting the issue to the assessee which is not a justified approach. - AT
Note: It is a system-generated summary and is for quick reference only.