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...
Levy of penalty u/s 271(1)(c) - assessment based on estimated income - professional entry operator - Nothing emerges from record that the assessee agreed to the addition to buy peace of mind and to avoid litigation - levy of penalty confirmed - AT
Levy of penalty u/s 271(1)(c) - assessment based on estimated income - professional entry operator - Nothing emerges from record that the assessee agreed to the addition to buy peace of mind and to avoid litigation - levy of penalty confirmed - AT
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