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 or 153C - assessment proceedings were initiated mainly on the information found during the search proceedings - jurisdiction lies to initiate proceedings u/s.153C and not u/s.148 - assessment made by the AO u/s 143(3) r.w.s. 147 quashed
Reopening of assessment u/s 147 or 153C - assessment proceedings were initiated mainly on the information found during the search proceedings - jurisdiction lies to initiate proceedings u/s.153C and not u/s.148 - assessment made by the AO u/s 143(3) r.w.s. 147 quashed
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