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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Reassessment - though the amendment u/s 115JA / 115JB was made with retrospective effect, the critical date is the date on which the AO exercises jurisdiction u/s 148 - the subsequent amendment could not have been and is in fact not a ground on which the AO sought to reopen the assessment - HC
Reassessment - though the amendment u/s 115JA / 115JB was made with retrospective effect, the critical date is the date on which the AO exercises jurisdiction u/s 148 - the subsequent amendment could not have been and is in fact not a ground on which the AO sought to reopen the assessment - HC
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