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...
Ex parte GST adjudication may warrant fresh consideration where a taxpayer did not answer a show-cause notice or contest proceedings because of asserted health-related inability. A justice-oriented approach supports reopening from the reply stage, permitting submission of supporting material and a reasonable hearing. A limitation-based dismissal of the statutory appeal did not involve examination on merits; the procedural focus is restoration of an effective opportunity to reply and be heard.
Ex parte GST adjudication may warrant fresh consideration where a taxpayer did not answer a show-cause notice or contest proceedings because of asserted health-related inability. A justice-oriented approach supports reopening from the reply stage, permitting submission of supporting material and a reasonable hearing. A limitation-based dismissal of the statutory appeal did not involve examination on merits; the procedural focus is restoration of an effective opportunity to reply and be heard.
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