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...
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
Pre-reassessment procedure requires the Assessing Officer to issue a show-cause notice, consider the taxpayer's reply and form only a prima facie view that income has escaped assessment. Absence of an oral hearing at that preliminary stage does not by itself invalidate the pre-reassessment order or consequential reassessment notice where a substantive opportunity remains available during reassessment. Information concerning unsecured loans and cash deposits may be considered collectively where intrinsically connected to the alleged escaped income; the genuineness of the loan is to be examined in reassessment. The reassessment must provide a meaningful personal hearing and consider further documents and explanations, with merits left open.
Note: It is a system-generated summary and is for quick reference only.
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