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...
Penalty u/s. 271(1)(c) - assessment u/s 153A - the incorrect claim did not get noticed either by the assessee or by the AO and its correction at the time of filing of return u/s 153A would not lead to imposition of penalty u/s 271(1)(c)- AT
Penalty u/s. 271(1)(c) - assessment u/s 153A - the incorrect claim did not get noticed either by the assessee or by the AO and its correction at the time of filing of return u/s 153A would not lead to imposition of penalty u/s 271(1)(c)- AT
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