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...
Protective addition - Addition of undisclosed income (on money consideration received by the assessee) - no similar addition was made in the hands of partners in their individual accounts - assessee firm was merely a confirming party and no consideration was received by the assessee firm - ITAT has correctly deleted the additions.
Protective addition - Addition of undisclosed income (on money consideration received by the assessee) - no similar addition was made in the hands of partners in their individual accounts - assessee firm was merely a confirming party and no consideration was received by the assessee firm - ITAT has correctly deleted the additions.
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