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...
Reopening of assessment u/s 147 - Computation of book profits u/s 115JB - MAT - if AO during scrutiny assessment notices a claim of exemptions made by the assessee having some prima facie doubt and asking the assessee to satisfy him with respect to such a claim and thereafter, does not make any addition in the final order of assessment, he can be stated to have formed an opinion whether or not in the final order he gives his reasons for not making the addition - HC
Reopening of assessment u/s 147 - Computation of book profits u/s 115JB - MAT - if AO during scrutiny assessment notices a claim of exemptions made by the assessee having some prima facie doubt and asking the assessee to satisfy him with respect to such a claim and thereafter, does not make any addition in the final order of assessment, he can be stated to have formed an opinion whether or not in the final order he gives his reasons for not making the addition - HC
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