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 - case of “no enquiry” - admittedly Assessing Officer at assessment stage has not verified amount shown under “suspense account”. It is very apparent that Assessing Officer has not verified its sources and mode of deposit - revision proceedings upheld.
Revision u/s 263 - case of “no enquiry” - admittedly Assessing Officer at assessment stage has not verified amount shown under “suspense account”. It is very apparent that Assessing Officer has not verified its sources and mode of deposit - revision proceedings upheld.
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