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...
Levy of penalty u/s. 271B - failure to get his books audited and furnish Audit Report u/s. 44AB - Section 271B as extracted above further throws light on the legislative intent as it specifically provides that no penalty "shall’ be imposed if the assessee proves "that there was reasonable cause for the said failure". - the explanations offered by the assessee have been ignored by the AO and CIT(A) - Penalty deleted - AT
Levy of penalty u/s. 271B - failure to get his books audited and furnish Audit Report u/s. 44AB - Section 271B as extracted above further throws light on the legislative intent as it specifically provides that no penalty "shall’ be imposed if the assessee proves "that there was reasonable cause for the said failure". - the explanations offered by the assessee have been ignored by the AO and CIT(A) - Penalty deleted - AT
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