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...
Reopening u/s 147 - validity of notice u/s 148 - original assessment u/s 143(1) - "change of the opinion" - High Court was not justified in dismissing the appeal on the ground that the appeal did not involve any substantial question of law.
Reopening u/s 147 - validity of notice u/s 148 - original assessment u/s 143(1) - "change of the opinion" - High Court was not justified in dismissing the appeal on the ground that the appeal did not involve any substantial question of law.
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