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...
Revision u/s 263 - source of purchase declared was examined by AO but unrealistically lower costs of purchases not examined - no relevant meaningful inquiry was conducted in respect to correctness of the cost of purchase of land - lack of inquiry - Revision justified
Revision u/s 263 - source of purchase declared was examined by AO but unrealistically lower costs of purchases not examined - no relevant meaningful inquiry was conducted in respect to correctness of the cost of purchase of land - lack of inquiry - Revision justified
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