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 - addition u/s. 68 - This is not a case of non-enquiry or non-application of mind. The Assessing Officer has examined all the evidences and taken a possible view. Just because the total income determined by the Assessing Officer in the second round of assessment proceedings, is less than the income determined in the first assessment proceedings, the order does not become erroneous. - AT
Revision u/s 263 - addition u/s. 68 - This is not a case of non-enquiry or non-application of mind. The Assessing Officer has examined all the evidences and taken a possible view. Just because the total income determined by the Assessing Officer in the second round of assessment proceedings, is less than the income determined in the first assessment proceedings, the order does not become erroneous. - AT
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