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 of unapproved purchases based on peak calculation - the aforesaid addition is not based on any incriminating documents or material found during the course of search, albeit is has been made on the basis of search conducted after more than 2 years in case of different persons and based on certain information received on 24.03.2014 - the same is outside purview and the addition made u/s 153A is unabated assessment. - AT
Assessment u/s 153A - Addition of unapproved purchases based on peak calculation - the aforesaid addition is not based on any incriminating documents or material found during the course of search, albeit is has been made on the basis of search conducted after more than 2 years in case of different persons and based on certain information received on 24.03.2014 - the same is outside purview and the addition made u/s 153A is unabated assessment. - AT
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