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...
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
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