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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
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