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...
Assessment completed u/s 153C - Limitation for completion of assessment - Correct date of search - once it is held that the present assessment year i.e., A.Y 2014-15 is the year of search, then the limitation for completion of assessment in the instant case expires on 31.03.2016. - Since the AO in the instant case has passed the order on 30.08.2016, therefore, the same is barred by limitation. - AT
Assessment completed u/s 153C - Limitation for completion of assessment - Correct date of search - once it is held that the present assessment year i.e., A.Y 2014-15 is the year of search, then the limitation for completion of assessment in the instant case expires on 31.03.2016. - Since the AO in the instant case has passed the order on 30.08.2016, therefore, the same is barred by limitation. - AT
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