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 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
Reopening of assessment u/s 147 - Validity of reasons to believe - non disposing of objections - Change of opinion - As held by the Supreme Court, it is not for the assessee to tell as to how the Assessing Officer has to complete the assessment. - It would be a clear case of change of opinion. What the Assessing Officer purported to do is to review his earlier decision. - proceedings of reopening quashed - HC
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