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...
Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
Power of Tribunal for enhancement - The AO at no point of time, disputed the date on which the business of the assessee was set up but disputed allowability of certain expenses on ground that assessee not commenced its commercial activity - Tribunal has no jurisdiction in venturing into an issue which was never an issue before the AO and cannot take away the benefit given to the assessee by the AO
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