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...
Revision u/s 263 - notice not signed by CIT - SCN was issued by Income Tax Officer (Technical) - as per Section 263 CIT cannot delegate his powers to the subordinate Officer or lower officer and, therefore, this defect is non-curable defect and the Show Cause Notice itself is bad in law - revision proceedings does not survive
Revision u/s 263 - notice not signed by CIT - SCN was issued by Income Tax Officer (Technical) - as per Section 263 CIT cannot delegate his powers to the subordinate Officer or lower officer and, therefore, this defect is non-curable defect and the Show Cause Notice itself is bad in law - revision proceedings does not survive
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