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...
Validity of assessment order - period of limitation - CIT(A) annulled the assessment order - Settlement Commission rejected the application on the grounds that the admitted tax and interest on the income disclosed had not been paid - Since AO has passed the order within 60 days from from the order of the ITSC, the order of CIT(A) cannot be sustained.
Validity of assessment order - period of limitation - CIT(A) annulled the assessment order - Settlement Commission rejected the application on the grounds that the admitted tax and interest on the income disclosed had not been paid - Since AO has passed the order within 60 days from from the order of the ITSC, the order of CIT(A) cannot be sustained.
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