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...
Period of limitation for revision u/s 263 - held that:- limitation would be counted from the reassessment order passed u/s 143(3) r.w.s 147 being the first regular assessment. - AT
Period of limitation for revision u/s 263 - held that:- limitation would be counted from the reassessment order passed u/s 143(3) r.w.s 147 being the first regular assessment. - AT
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