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 - Notice u/s 148-A - Reason to believe - Source of information is not relevant. What is relevant is the tangible material against the appellant. The petitioner did not even submit bank statements or the books of accounts. - There is, prima facie, some material on the basis of which the Department could reopen the case. - Writ Petition dismissed - Notice sustained - HC
Reopening of assessment u/s 147 - Notice u/s 148-A - Reason to believe - Source of information is not relevant. What is relevant is the tangible material against the appellant. The petitioner did not even submit bank statements or the books of accounts. - There is, prima facie, some material on the basis of which the Department could reopen the case. - Writ Petition dismissed - Notice sustained - HC
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