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...
Maintainability of appeal before ITAT - Commissioner (Appeals) need to be approached first - The order sought to be impugned in this appeal is passed by the AO and, therefore, this exception does not come into play. Learned counsel’s understanding of the legal position, even if bonafide- particularly considering his young age and limited experience, is clearly incorrect. The appeal filed before us is thus indeed not maintainable in law. - AT
Maintainability of appeal before ITAT - Commissioner (Appeals) need to be approached first - The order sought to be impugned in this appeal is passed by the AO and, therefore, this exception does not come into play. Learned counsel’s understanding of the legal position, even if bonafide- particularly considering his young age and limited experience, is clearly incorrect. The appeal filed before us is thus indeed not maintainable in law. - AT
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