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...
Maintainability of the appeal u/s 260A before HC whereas the rectification application u/s 254(2) is pending before the ITAT - there are substantial questions of law to be decided, hence pendency of a petition for rectification u/s 254(2) can have no impact - appeal is maintainable.
Maintainability of the appeal u/s 260A before HC whereas the rectification application u/s 254(2) is pending before the ITAT - there are substantial questions of law to be decided, hence pendency of a petition for rectification u/s 254(2) can have no impact - appeal is maintainable.
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