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...
Assessment u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
Assessment u/s 153C - Since a response was on record, undoubtedly, the AO was required to issue a notice under Section 143(2) of the Act and then proceed further in the matter, and perhaps thereafter, frame an assessment u/s 147 read with Section 144 of the Act. This was not done. - for the AO to take recourse to Section 144 of the Act was completely uncalled. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
