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 Best judgment assessment - Assessment u/s 153C - since petitioner has filed a return, no best judgment assessment u/s 144 of the Act could have been passed - So far as, the provisions of Section 144(1)(b) of the Act are concerned, as explained hereinabove, there has been no failure to comply with the terms of any notice issued under Section 142(1) of the Act. Therefore, the purported exercise of powers u/s144 of the Act cannot be sustained. - HC
Validity of Best judgment assessment - Assessment u/s 153C - since petitioner has filed a return, no best judgment assessment u/s 144 of the Act could have been passed - So far as, the provisions of Section 144(1)(b) of the Act are concerned, as explained hereinabove, there has been no failure to comply with the terms of any notice issued under Section 142(1) of the Act. Therefore, the purported exercise of powers u/s144 of the Act cannot be sustained. - HC
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