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...
Levy of penalty u/s 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
Levy of penalty u/s 271AAA - Addition u/s 69A post search - assessee’s argument that the assessee’s explanation has not been found to be false and, therefore, penalty is not sustainable is not acceptable.
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