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    Permanent establishment taxation addresses head-office interest, arm's length guarantees, capital hedges, refund interest, and treaty tax ceilings.
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      Fraud-account classification requires a reasoned order showing...

      Reasoned fraud classification requires disclosed application of mind, while adequate prior opportunity satisfies natural justice requirements.

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      IBCAugust 8, 2026Case LawsHC
      Fraud-account classification requires a reasoned order showing due application of mind, although the reasons need not match the detail of a judicial judgment. The order identified grounds under the Fraud Master Circular and recorded audit findings on diversion of funds through an undisclosed account, related-party transactions, unjustified transfers and interest-free advances; it was therefore adequately reasoned. Natural justice was not breached because the petitioners had received and discussed the draft audit report, had opportunities to provide material, and received the final report with the show-cause notice. The HC dismissed the writ petition, upholding the fraud classification.

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      ActsIncome Tax