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 - assumption of revisionary jurisdiction by PCIT - once the revenue has accepted the income from trading in commodity on NSEL as business income, then loss which arise from the NSEL trading cannot be termed as Speculation loss. Consequently, the view taken by the AO cannot the termed as erroneous. - AT
Revision u/s 263 - assumption of revisionary jurisdiction by PCIT - once the revenue has accepted the income from trading in commodity on NSEL as business income, then loss which arise from the NSEL trading cannot be termed as Speculation loss. Consequently, the view taken by the AO cannot the termed as erroneous. - AT
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