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 u/s 153A - Addition made without any incriminating document or not - Accommodation entry - the ld.CIT(A) has elaborately discussed the incriminating evidences found from the premises of the assessee at page 12 of his order which clearly demonstrate that the assessee had availed accommodation entries in respect of capital assets as well as raw material purchases. - Order of CIT(A) sustained - AT
Assessment u/s 153A - Addition made without any incriminating document or not - Accommodation entry - the ld.CIT(A) has elaborately discussed the incriminating evidences found from the premises of the assessee at page 12 of his order which clearly demonstrate that the assessee had availed accommodation entries in respect of capital assets as well as raw material purchases. - Order of CIT(A) sustained - AT
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