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 - requirement of giving minimum of 7 days notice - While redoing the exercise, it is open to the respondent to issue a notice afresh u/s 148B giving not less than 7 days to the petitioner/assessee to respond and on receipt of the same, the petitioner shall respond by giving their reply or inputs within the time stipulated therein. - HC
Reopening of assessment u/s 147 - requirement of giving minimum of 7 days notice - While redoing the exercise, it is open to the respondent to issue a notice afresh u/s 148B giving not less than 7 days to the petitioner/assessee to respond and on receipt of the same, the petitioner shall respond by giving their reply or inputs within the time stipulated therein. - HC
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