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 271(1)(b) - Best judgment assessment - email notices sent to old ITP’s email address - without proper service of notices to the assessee, the assessee cannot be levied with penalty under Section 271(1)(b) for non-compliance of such notices. - AT
Levy of penalty u/s 271(1)(b) - Best judgment assessment - email notices sent to old ITP’s email address - without proper service of notices to the assessee, the assessee cannot be levied with penalty under Section 271(1)(b) for non-compliance of such notices. - AT
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