Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
The information / knowledge available to the assessee was made through a licence; consequently, it is covered under the definition of “royalty“ under the domestic law under section 19(1)(iv) and (vi) along with article 13(3) of the Double Taxation Avoidance Agreement with the U.K- AT
The information / knowledge available to the assessee was made through a licence; consequently, it is covered under the definition of “royalty“ under the domestic law under section 19(1)(iv) and (vi) along with article 13(3) of the Double Taxation Avoidance Agreement with the U.K- AT
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