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 - If it is found by the Assessing Officer on such verification that the amount in question represents the sale proceeds of investments which were made by the assessee out of share capital and share premium amounting to ₹ 11.04 crores, which is already treated and accepted as income of the assessee by virtue of the settlement of dispute under Vivad Se Vishwas Scheme in A.Y. 2008-09, the same cannot be treated as income of the assessee again for the year under consideration as the same would amount to double addition. - AT
Reopening of assessment u/s 147 - If it is found by the Assessing Officer on such verification that the amount in question represents the sale proceeds of investments which were made by the assessee out of share capital and share premium amounting to ₹ 11.04 crores, which is already treated and accepted as income of the assessee by virtue of the settlement of dispute under Vivad Se Vishwas Scheme in A.Y. 2008-09, the same cannot be treated as income of the assessee again for the year under consideration as the same would amount to double addition. - AT
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