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...
Unaccounted investment u/s. 69C - The ITAT observed that the confusion arose because the assessee had treated the total booking amount (creditors) as closing work in progress, which the AO considered as unexplained investment. - The ITAT upheld the CIT(A)'s decision in deleting the addition, stating that the amount had already been offered for tax as gross profits.
Unaccounted investment u/s. 69C - The ITAT observed that the confusion arose because the assessee had treated the total booking amount (creditors) as closing work in progress, which the AO considered as unexplained investment. - The ITAT upheld the CIT(A)'s decision in deleting the addition, stating that the amount had already been offered for tax as gross profits.
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