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...
Addition u/s 69C - value of asset bought from the vendor who is alleged to be a suspicious dealer - disallowance of depreciation on the asset above - the AO cannot disallow the total value of the asset and also simultaneously disallow the depreciation claimed by the assessee. The disallowance can only be made to the extent of the benefit claimed by the assessee under the Act. - AT
Addition u/s 69C - value of asset bought from the vendor who is alleged to be a suspicious dealer - disallowance of depreciation on the asset above - the AO cannot disallow the total value of the asset and also simultaneously disallow the depreciation claimed by the assessee. The disallowance can only be made to the extent of the benefit claimed by the assessee under the Act. - AT
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