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 - the duty of the AO is only to primafacie establish that income chargeable to tax has escaped assessment - it would not be his duty to demonstrate with certainty that invariably upon reassessment additions would be stand - HC
Reopening of assessment u/s 147 - the duty of the AO is only to primafacie establish that income chargeable to tax has escaped assessment - it would not be his duty to demonstrate with certainty that invariably upon reassessment additions would be stand - HC
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