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Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
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Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Assessment proceedings issued in the name of a deceased assessee were unsustainable where the death certificate and legal heir certificate showed that death had occurred before the assessment order. The High Court set aside the impugned order because it could not validly be made against a dead person, but left the respondent free to start fresh proceedings against all legal representatives after issuing notice in accordance with the legal heir certificate.
Assessment proceedings issued in the name of a deceased assessee were unsustainable where the death certificate and legal heir certificate showed that death had occurred before the assessment order. The High Court set aside the impugned order because it could not validly be made against a dead person, but left the respondent free to start fresh proceedings against all legal representatives after issuing notice in accordance with the legal heir certificate.
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