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...
Estimation of income - bogus purchases - when the purchases are held to be bogus and only certain percentage only to be disallowed - assessee has already declared profit @ 9% (confirmed by AO) the net difference of 3.5% (12.5 - 9) should be considered for disallowance. Accordingly, we direct Assessing Officer to disallow @ 3.5% of the alleged bogus purchases. - AT
Estimation of income - bogus purchases - when the purchases are held to be bogus and only certain percentage only to be disallowed - assessee has already declared profit @ 9% (confirmed by AO) the net difference of 3.5% (12.5 - 9) should be considered for disallowance. Accordingly, we direct Assessing Officer to disallow @ 3.5% of the alleged bogus purchases. - AT
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