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...
Power of CIT(A) u/s 151 - enhancement of income - CIT(A) has erred in exceeding his jurisdiction by enhancing income from a fresh source that was neither part of return of income nor touched upon by the Assessing Officer in proceeding u/s. 143(3).
Power of CIT(A) u/s 151 - enhancement of income - CIT(A) has erred in exceeding his jurisdiction by enhancing income from a fresh source that was neither part of return of income nor touched upon by the Assessing Officer in proceeding u/s. 143(3).
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