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...
Revision u/s 263 - There cannot be any estoppel against law and method of accounting/policy followed by tax-payer which is contrary to law even if accepted by the AO after due enquiry cannot be said to be a view which could be said to be one of the possible or a plausible view - view of the Ld. CIT cannot be held to be merely a change of opinion - revision upheld
Revision u/s 263 - There cannot be any estoppel against law and method of accounting/policy followed by tax-payer which is contrary to law even if accepted by the AO after due enquiry cannot be said to be a view which could be said to be one of the possible or a plausible view - view of the Ld. CIT cannot be held to be merely a change of opinion - revision upheld
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
