Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
Receipts from standard software licences or subscriptions, together with incidental support services, were held not to constitute fees for technical services because the offerings were standardised and automated, with only a limited, non-transferable right of access or use and no transfer of source code, proprietary rights, or commercial exploitation rights. The related support was treated as ancillary to the software supply, not as separate managerial, technical, or consultancy services. On that basis, the software-related addition was deleted for A.Y. 2020-21, and the same reasoning was applied to A.Y. 2021-22. The refund adjustment issue was not decided on merits and was remanded for limited verification and consequential relief, if due.
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