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...
Rectification of mistake u/s 154 - withdrawal of TDS credit in an order u/s 154 after allowing the same in 143(3) on the ground that corresponding income has not been offered for tax in the relevant assessment year is debatable issue - rectification not permissible.
Rectification of mistake u/s 154 - withdrawal of TDS credit in an order u/s 154 after allowing the same in 143(3) on the ground that corresponding income has not been offered for tax in the relevant assessment year is debatable issue - rectification not permissible.
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