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/153C - The three conditions operate on a stand-alone basis, separated by the conjunction 'or', and not concurrently and the satisfaction or otherwise of any one of the three conditions would suffice to decide the question of jurisdiction. - In the case of the petitioner the return has been filed on 26.09.2018 u/s 139(4), and is thus a valid return. Notice under Section 143(2) has been issued on 27.08.2019, also within time. Condition (b) is thus not satisfied and no proceedings may be initiated u/s 153C. - HC
Assessment u/s 153A/153C - The three conditions operate on a stand-alone basis, separated by the conjunction 'or', and not concurrently and the satisfaction or otherwise of any one of the three conditions would suffice to decide the question of jurisdiction. - In the case of the petitioner the return has been filed on 26.09.2018 u/s 139(4), and is thus a valid return. Notice under Section 143(2) has been issued on 27.08.2019, also within time. Condition (b) is thus not satisfied and no proceedings may be initiated u/s 153C. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
