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 Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
Validity of Penalty u/s 271D and u/s 271E - Penalty proceeding as independent of the assessment proceeding - absence of satisfaction recorded in the reassessment u/s 147 r.w.s 144 r.w.s. 144B - The tribunal, following the Judgement of Supreme Court, confirmed the order of CIT(A) for deleting the penalty on account of no satisfaction recorded by the Ld. AO in the reassessment order u/s 147 r.w.s. 144 r.w.s. 144B.
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