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...
Addition of interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
Addition of interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
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