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...
Reopening of assessment - It was clear that A.O. recorded incorrect and non-existing reasons for reopening of the assessment. Therefore, on the face of it, the reopening of the assessment is void and bad in law. - AT
Reopening of assessment - It was clear that A.O. recorded incorrect and non-existing reasons for reopening of the assessment. Therefore, on the face of it, the reopening of the assessment is void and bad in law. - AT
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