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 - 'reason to believe' or 'reason to suspect' - objections of the petitioner were rejected by a non-speaking and cryptic order - information already available on record - merely because there is a change in opinion, reopening could not have been done
Reopening of assessment u/s 147 - 'reason to believe' or 'reason to suspect' - objections of the petitioner were rejected by a non-speaking and cryptic order - information already available on record - merely because there is a change in opinion, reopening could not have been done
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