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 271AAA - disclosure of unaccounted income during search - assessee did not specify how she derived that income and what head it fell in (rent, capital gain, professional or business income out of money lending, source of the money etc) - the lower appellate authorities misdirected themselves in holding that the conditions in Section 271AAA (2) were satisfied by the assessee. - HC
Penalty u/s 271AAA - disclosure of unaccounted income during search - assessee did not specify how she derived that income and what head it fell in (rent, capital gain, professional or business income out of money lending, source of the money etc) - the lower appellate authorities misdirected themselves in holding that the conditions in Section 271AAA (2) were satisfied by the assessee. - HC
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