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...
Extended period of limitation - Revenue started investigations vide their letter dated November, 2007 and thereafter kept quiet for a period of almost five years and issued show cause notice only on 24.06.2011. There is no explanation by the Revenue for the such delayed issuance of show cause notice - Demand set aside.
Extended period of limitation - Revenue started investigations vide their letter dated November, 2007 and thereafter kept quiet for a period of almost five years and issued show cause notice only on 24.06.2011. There is no explanation by the Revenue for the such delayed issuance of show cause notice - Demand set aside.
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