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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Reassessment u/s 147 - In ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
Reassessment u/s 147 - In ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
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