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 ...
Revision u/s 264 in favor of assessee - period of limitation - the petitioner cannot be shut out from placing facts before the Commissioner and Section 264 empowers the Commissioner to cause enquiry and verify the facts. Secondly, if there has been a genuine mistake committed by the assessee, Statute does not bar the assessee from rectifying his mistake - HC
Revision u/s 264 in favor of assessee - period of limitation - the petitioner cannot be shut out from placing facts before the Commissioner and Section 264 empowers the Commissioner to cause enquiry and verify the facts. Secondly, if there has been a genuine mistake committed by the assessee, Statute does not bar the assessee from rectifying his mistake - HC
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