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...
Validity of the re-opening of the assessment - non-issuance of notice u/s. 143(2) - In the absence of such notice, it is presumed that AO did not issue any notice u/s. 143(2) of the Act, hence the assessment was framed without meeting the requirement of law. - assessment order quashed being bad in law - AT
Validity of the re-opening of the assessment - non-issuance of notice u/s. 143(2) - In the absence of such notice, it is presumed that AO did not issue any notice u/s. 143(2) of the Act, hence the assessment was framed without meeting the requirement of law. - assessment order quashed being bad in law - AT
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