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 ...
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
The action of reopening of assessment can be resorted to by the AO only if he has tangible material at his command to form a reasonable belief that income chargeable to tax had escaped assessment. Such belief of the AO cannot be substituted by that of the opinion of the audit party - HC
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