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 undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
Addition of undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
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