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...
Territorial jurisdiction defect rendered the assessment invalid where the assessee's case remained with the Mumbai Assessing Officer and no transfer order for the relevant year was shown. The Tribunal noted that the assessee had been assessed by Mumbai in the preceding and succeeding years, and that the Delhi Assessing Officer therefore lacked authority to frame the order. It further held that the bar on belated objections to jurisdiction did not cure an inherent lack of jurisdiction, so the impugned orders were set aside and the other grounds were left academic.
Territorial jurisdiction defect rendered the assessment invalid where the assessee's case remained with the Mumbai Assessing Officer and no transfer order for the relevant year was shown. The Tribunal noted that the assessee had been assessed by Mumbai in the preceding and succeeding years, and that the Delhi Assessing Officer therefore lacked authority to frame the order. It further held that the bar on belated objections to jurisdiction did not cure an inherent lack of jurisdiction, so the impugned orders were set aside and the other grounds were left academic.
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