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...
Revision u/s 263 - AO failed to apply his mind to the case in all perspective in terms of conditions contemplated in provisions u/s. 54F - He accepted the claim of assessee in the absence of any inquiry - Revision order sustained.
Revision u/s 263 - AO failed to apply his mind to the case in all perspective in terms of conditions contemplated in provisions u/s. 54F - He accepted the claim of assessee in the absence of any inquiry - Revision order sustained.
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