Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
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