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...
Revision u/s 263 - It is settled principle of law that once the High Court lays down particular the proposition of law, the same is deemed to be in existence from the inception. Fact would clearly suggest that there was no material on record to hold that the legal and professional expenses are not allowable as revenue expenditure. AO only took one of the possible views and, therefore, the Pr. CIT was not justified in exercising the power of revision - AT
Revision u/s 263 - It is settled principle of law that once the High Court lays down particular the proposition of law, the same is deemed to be in existence from the inception. Fact would clearly suggest that there was no material on record to hold that the legal and professional expenses are not allowable as revenue expenditure. AO only took one of the possible views and, therefore, the Pr. CIT was not justified in exercising the power of revision - AT
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