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...
Penalty u/s. 271A - confusion between the ‘books of account’ as per section 44AA and the ‘accounts’ as per section 145(3) - no finding either by the AO or by the CIT(A) that books or documents being not maintained by the assessee - not maintaining ‘proper accounts' will not attract penalty u/s. 271A
Penalty u/s. 271A - confusion between the ‘books of account’ as per section 44AA and the ‘accounts’ as per section 145(3) - no finding either by the AO or by the CIT(A) that books or documents being not maintained by the assessee - not maintaining ‘proper accounts' will not attract penalty u/s. 271A
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