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 ...
Expansion of scrutiny from the ‘Limited Scrutiny’ to ‘Complete Scrutiny - Addition u/s 68 - Since the CBDT Circular issued u/s. 119 of the Act is binding on the department/AO, the AO was bound by it and without taking approval in writing from Pr CIT/CIT could not have enquired into other issues other than the issue for which the assessment was selected for Limited Scrutiny.
Expansion of scrutiny from the ‘Limited Scrutiny’ to ‘Complete Scrutiny - Addition u/s 68 - Since the CBDT Circular issued u/s. 119 of the Act is binding on the department/AO, the AO was bound by it and without taking approval in writing from Pr CIT/CIT could not have enquired into other issues other than the issue for which the assessment was selected for Limited Scrutiny.
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