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...
Revision u/s 263 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
Revision u/s 263 - PCIT observed that AO had failed to examine and verify the issues related to share premium received and interest earned, which issues had remained unaddressed - The action of the Ld. PCIT is in direct contravention of the provisions of Explanation (a)(i) to section 56(2)(vii) of the I.T. Act read with rule 11UA(2)(b) of the I.T. Rules. - AO could not have changed the method of valuation opted by the Assessee - Revision order quashed - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
