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...
Jurisdiction of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
Jurisdiction of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
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