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...
The claim of the assessee cannot be considered as false to attract the rigours of penalty u/s 271(1)( c) which is quasi criminal in nature and accordingly deleted the penalty. - AT
The claim of the assessee cannot be considered as false to attract the rigours of penalty u/s 271(1)( c) which is quasi criminal in nature and accordingly deleted the penalty. - AT
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