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...
Revision u/s 263 - Exemption u/s 10(23FB) - income earned out of investments made in Venture Capital Undertakings (VCU) - the assessee is bound to succeed both on the issue of exercise of jurisdiction under section 263 of the Act as well as on the merits of allowability of exemption under section 10(23FB) of the Act.
Revision u/s 263 - Exemption u/s 10(23FB) - income earned out of investments made in Venture Capital Undertakings (VCU) - the assessee is bound to succeed both on the issue of exercise of jurisdiction under section 263 of the Act as well as on the merits of allowability of exemption under section 10(23FB) of the Act.
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