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...
Reopening of assessment u/s 147 - Disallowance u/s. 40(a)(ia) - TDS on rent - Normally whenever any irregularity crept in the proceedings, then after removing the irregularities, proceedings is to be initiated from that stage but by remitting the issue to the ld. first appellate authority we would be multiplying the litigation, because the ld. CIT(A) would call for a remand report from the Assessing Officer and proceedings would commence on two stages in order to avoid that situation we would deem it proper to set aside order of both the revenue authorities and remit all the issues to the Assessing Officer. - AT
Reopening of assessment u/s 147 - Disallowance u/s. 40(a)(ia) - TDS on rent - Normally whenever any irregularity crept in the proceedings, then after removing the irregularities, proceedings is to be initiated from that stage but by remitting the issue to the ld. first appellate authority we would be multiplying the litigation, because the ld. CIT(A) would call for a remand report from the Assessing Officer and proceedings would commence on two stages in order to avoid that situation we would deem it proper to set aside order of both the revenue authorities and remit all the issues to the Assessing Officer. - AT
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