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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Consequential assessment orders allowing verified purchase expenditure in full bind the Department, leaving it without an aggrieved claim against the allowance. Where an earlier remand required fresh inquiry into allegedly unsubstantiated or inflated purchases, the Assessing Officer's subsequent verification and full acceptance of the claims rendered the surviving purchase-disallowance controversy infructuous. A favourable remand report, and more strongly a consequential assessment order, prevents the Department from contesting the allowance. The purchase disallowances partly sustained at first appeal were therefore deleted fully, the assessee's appeals succeeded on this issue, and the corresponding Revenue grounds failed.
Consequential assessment orders allowing verified purchase expenditure in full bind the Department, leaving it without an aggrieved claim against the allowance. Where an earlier remand required fresh inquiry into allegedly unsubstantiated or inflated purchases, the Assessing Officer's subsequent verification and full acceptance of the claims rendered the surviving purchase-disallowance controversy infructuous. A favourable remand report, and more strongly a consequential assessment order, prevents the Department from contesting the allowance. The purchase disallowances partly sustained at first appeal were therefore deleted fully, the assessee's appeals succeeded on this issue, and the corresponding Revenue grounds failed.
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