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...
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
An adjudicatory order must deal with the pleadings and record reasons for accepting or rejecting the reliefs sought; failure to consider the contentions raised and the remaining prayers renders the order non-speaking and vitiated for non-application of mind. As the impugned order granted only part of the relief without addressing the balance claims on merits, it was quashed and the application was remitted for fresh decision, without expressing any view on the underlying merits.
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