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 - assessee has not been able to show any reasonable cause for not complying with Rules nor for its failure to produce information called for by the ld. TPO. - levy of penalty u/s 271AA as well as 271G of the Act were justified.
Penalty - assessee has not been able to show any reasonable cause for not complying with Rules nor for its failure to produce information called for by the ld. TPO. - levy of penalty u/s 271AA as well as 271G of the Act were justified.
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