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...
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
Jurisdictional objections in reassessment, including a notice issued in the name of a deceased assessee and alleged procedural non-compliance, must be addressed before merits where they could invalidate the reassessment. Section 250(6) requires the appellate authority to identify each point for determination, record its decision and provide reasons; a general reference to the assessment order does not constitute ground-wise reasoned adjudication. The authority's power to set aside a best-judgment assessment does not remove this obligation. Jurisdictional and legal grounds should be decided through a speaking order before additions are examined on merits, which arise only if the reassessment is valid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
