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...
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Note: It is a system-generated summary and is for quick reference only.