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...
Reopening of assessment u/s 147 - There is a difference between the power to review and power to reassess - Placing such a restriction on the power of assessment of the assessing authority is contrary to the scheme of the Act, besides would operate to cause prejudice to the Revenue - AT
Reopening of assessment u/s 147 - There is a difference between the power to review and power to reassess - Placing such a restriction on the power of assessment of the assessing authority is contrary to the scheme of the Act, besides would operate to cause prejudice to the Revenue - AT
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