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 ...
Reopening of assessment u/s 147 - AO has re-appreciated trial balance-sheet which is also available to him when original assessment order was passed and alleged escapement - proviso appended to section 147 puts an embargo in the exercise of power of AO in cases where scrutiny assessment has taken place and four years have expired from the end of relevant AY if assessee has disclosed all material facts fully and truly - reassessment quashed
Reopening of assessment u/s 147 - AO has re-appreciated trial balance-sheet which is also available to him when original assessment order was passed and alleged escapement - proviso appended to section 147 puts an embargo in the exercise of power of AO in cases where scrutiny assessment has taken place and four years have expired from the end of relevant AY if assessee has disclosed all material facts fully and truly - reassessment quashed
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