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...
Validity of revision order u/s 263 - where exhaustive exercise has been done by the AO, the order of the AO in allowing the impugned loss could not have been held to be erroneous. - AT
Validity of revision order u/s 263 - where exhaustive exercise has been done by the AO, the order of the AO in allowing the impugned loss could not have been held to be erroneous. - AT
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