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...
Penalty u/s 158BFA(2) - no willful default - additions made were only due to the difference in estimate - It is never the case of the Revenue that the undisclosed income was on account of any transaction, which was out of books but, the entire case arose out of valuation of the gold jewellery and the diamonds - no penalty
Penalty u/s 158BFA(2) - no willful default - additions made were only due to the difference in estimate - It is never the case of the Revenue that the undisclosed income was on account of any transaction, which was out of books but, the entire case arose out of valuation of the gold jewellery and the diamonds - no penalty
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