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...
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
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