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 ...
Revision u/s 263 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
Revision u/s 263 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
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