Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
TDS u/s 195 - in the absence of the PE in India, the business profit of the non-resident is not taxable in India. - even if it is considered that the payments made to non-resident will fall under Article 22 of the Treaty viz. “Other Income“, then also not taxable in India - AT
TDS u/s 195 - in the absence of the PE in India, the business profit of the non-resident is not taxable in India. - even if it is considered that the payments made to non-resident will fall under Article 22 of the Treaty viz. “Other Income“, then also not taxable in India - AT
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