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...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Conversion of ‘limited scrutiny’ into ‘complete scrutiny’ - to cover the aspect of remuneration to partners - As the ld. CCIT did not make out any case of converting ‘limited scrutiny’ into ‘complete scrutiny’ as a ground for revision, we are afraid that the contention of the ld. DR on this score cannot be entertained. - AT
Conversion of ‘limited scrutiny’ into ‘complete scrutiny’ - to cover the aspect of remuneration to partners - As the ld. CCIT did not make out any case of converting ‘limited scrutiny’ into ‘complete scrutiny’ as a ground for revision, we are afraid that the contention of the ld. DR on this score cannot be entertained. - AT
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