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...
Reopening of assessment u/s 147 - original assessment u/s 143(3) - change of opinion - allegation of non-disclosure not find favour from court - Once there is finding that reasons to believe are not good reasons, jurisdiction is not derived to compel assessee to submit to reassessment.
Reopening of assessment u/s 147 - original assessment u/s 143(3) - change of opinion - allegation of non-disclosure not find favour from court - Once there is finding that reasons to believe are not good reasons, jurisdiction is not derived to compel assessee to submit to reassessment.
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