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 order passed u/s 154 - adjustment of cash seized against the advance tax denied - it has now been settled that insertion of Explanation 2 to Section 132B of the Act shall have a prospective application and so, appeals may not befiled by the Department on this issue for the cases prior to 01.06.2013 and those already filed may be withdrawn/ not pressed upon. - AT
Validity of order passed u/s 154 - adjustment of cash seized against the advance tax denied - it has now been settled that insertion of Explanation 2 to Section 132B of the Act shall have a prospective application and so, appeals may not befiled by the Department on this issue for the cases prior to 01.06.2013 and those already filed may be withdrawn/ not pressed upon. - AT
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