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...
Status of assessee as "AOP" instead of "partnership firm" - The assessee firm was comprised of four individual partners who were representing their respective firms - There was no justification on the part of the lower authorities to have recharacterized the assessee firm i.e. a firm comprising of individual partners (representing their respective firms) as an "AOP". - AT
Status of assessee as "AOP" instead of "partnership firm" - The assessee firm was comprised of four individual partners who were representing their respective firms - There was no justification on the part of the lower authorities to have recharacterized the assessee firm i.e. a firm comprising of individual partners (representing their respective firms) as an "AOP". - AT
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