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 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
Reopening of assessment u/s 147 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
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