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...
Validity of notice u/s 148 - AO has issued notice on 28.03.2014 though he has applied for approval which was granted on 29.03.2014 - very foundation for issuance of notice u/s 148 is the approval from the competent authority - in the absence of approval, such notice is void ab initio
Validity of notice u/s 148 - AO has issued notice on 28.03.2014 though he has applied for approval which was granted on 29.03.2014 - very foundation for issuance of notice u/s 148 is the approval from the competent authority - in the absence of approval, such notice is void ab initio
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