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 ...
When the appellant is a Govt. corporation, who paid entire tax demand (through may be some interest still remains payable as it was not quantified by the Revenue), before issue of SCN and where ‘intention to evade payment of tax’ cannot be alleged, then in the light of provisions of Section 73(3) and Section 80 of FA, 1994, no penalty is liable to be imposed on the assessee appellant - AT
When the appellant is a Govt. corporation, who paid entire tax demand (through may be some interest still remains payable as it was not quantified by the Revenue), before issue of SCN and where ‘intention to evade payment of tax’ cannot be alleged, then in the light of provisions of Section 73(3) and Section 80 of FA, 1994, no penalty is liable to be imposed on the assessee appellant - AT
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