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...
Under the new tax regime, the Tribunal treated a previously filed Form 10IE as continuing where the assessee had already exercised the option and had not withdrawn it. It noted that the claim under section 115BAC for A.Y. 2023-24 could not be rejected merely because no fresh Form 10IE was filed for that year. The return should not have been processed under the old regime on that basis, and the Assessing Officer was directed to allow taxation under the new regime on the strength of the form already available on record.
Under the new tax regime, the Tribunal treated a previously filed Form 10IE as continuing where the assessee had already exercised the option and had not withdrawn it. It noted that the claim under section 115BAC for A.Y. 2023-24 could not be rejected merely because no fresh Form 10IE was filed for that year. The return should not have been processed under the old regime on that basis, and the Assessing Officer was directed to allow taxation under the new regime on the strength of the form already available on record.
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