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 - the notice u/s. 143(2) of the Act, was issued much prior to the assessee filing his return of income. This is not in accordance with law. Hence the order passed u/s. 148 of the Act without issuing valid notice u/s. 143(2) of the Act, makes the reassessment order dt. 20/05/2016, passed u/s. 143(3)/147 of the Act, bad in law - Consequently, the revision of the assessment u/s. 263, revising such illegal assessment order is also bad in law. - AT
Revision u/s 263 - the notice u/s. 143(2) of the Act, was issued much prior to the assessee filing his return of income. This is not in accordance with law. Hence the order passed u/s. 148 of the Act without issuing valid notice u/s. 143(2) of the Act, makes the reassessment order dt. 20/05/2016, passed u/s. 143(3)/147 of the Act, bad in law - Consequently, the revision of the assessment u/s. 263, revising such illegal assessment order is also bad in law. - AT
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