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 Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
Validity of Assessment u/s 153C - Notice issued by any officer other than jurisdictional AO - the entire conspectus of the case, it appears that the AO had recorded the satisfaction note prior to assuming jurisdiction over the case of the assessee as the AO got charge over the case of the assessee on 02-09-2019 - CIT(A) is not justified in sustaining the action of the AO in holding that the AO has assumed proper jurisdiction to assess the case u/s. 153C - AT
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