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...
Reopening of assessment u/s 147 - when the issues were subject matter of appeal before the CIT(A) in the case of original assessment, the AO cannot re-visit the same by re-opening the assessment u/s. 147 and also in view of second proviso to section 147 - assessment order is quashed
Reopening of assessment u/s 147 - when the issues were subject matter of appeal before the CIT(A) in the case of original assessment, the AO cannot re-visit the same by re-opening the assessment u/s. 147 and also in view of second proviso to section 147 - assessment order is quashed
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