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...
For invoking jurisdiction under section 153C, satisfaction must be specific, based on cogent material, and must show that the seized material pertains to the assessee and affects total income for the relevant year. A common, mechanical satisfaction note covering multiple years, without year-specific incriminating documents or prima facie analysis of undisclosed income, was found insufficient. A third-party ledger, unsupported by independent corroboration or meaningful enquiry, was not treated as incriminating. Because the assessment year was unabated and year-specific satisfaction was absent, the notice and assessment were quashed, while the merits of the additions were left open.
For invoking jurisdiction under section 153C, satisfaction must be specific, based on cogent material, and must show that the seized material pertains to the assessee and affects total income for the relevant year. A common, mechanical satisfaction note covering multiple years, without year-specific incriminating documents or prima facie analysis of undisclosed income, was found insufficient. A third-party ledger, unsupported by independent corroboration or meaningful enquiry, was not treated as incriminating. Because the assessment year was unabated and year-specific satisfaction was absent, the notice and assessment were quashed, while the merits of the additions were left open.
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