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...
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
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