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...
Reassessment proceedings - during the pendency of the proceedings u/s 154 for rectification of error, it was not permissible on the part of the Revenue to initiate the proceedings u/s 147/148 of the Act - The High Court has erred in presuming and observing that the proceedings u/s 154 were invalid because the same were beyond the period of limitation. - SC
Reassessment proceedings - during the pendency of the proceedings u/s 154 for rectification of error, it was not permissible on the part of the Revenue to initiate the proceedings u/s 147/148 of the Act - The High Court has erred in presuming and observing that the proceedings u/s 154 were invalid because the same were beyond the period of limitation. - SC
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