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 SCN issued after undue delay - there is no prescribed period of limitation for completing an assessment, it does not mean that the power can be exercised at any time, it had to be exercised within a reasonable period - the delay of over nine years or over five years in issuing the SCNs have not been satisfactorily explained - SCN quashed
Validity of SCN issued after undue delay - there is no prescribed period of limitation for completing an assessment, it does not mean that the power can be exercised at any time, it had to be exercised within a reasonable period - the delay of over nine years or over five years in issuing the SCNs have not been satisfactorily explained - SCN quashed
Note: It is a system-generated summary and is for quick reference only.