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...
Reopening of the assessment U/S 147 - the High Court has quashed the show cause notice on the ground that the AO has accepted the claim of expenditures during scrutiny assessment u/s 143(3) - therefore the income escaping proceeding has been initiated marely on the basis of change of opinion and cannot sustain - the apex court refused to interfere in the decision of at HC - SC
Reopening of the assessment U/S 147 - the High Court has quashed the show cause notice on the ground that the AO has accepted the claim of expenditures during scrutiny assessment u/s 143(3) - therefore the income escaping proceeding has been initiated marely on the basis of change of opinion and cannot sustain - the apex court refused to interfere in the decision of at HC - SC
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