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 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
Revision u/s 263 - deduction under section 54B - No doubt the assessee declared capital gain but, whether its exemption can be claimed on purchase of other agriculture land, is not at all examined by the AO - the ld. PCIT validly assumed his jurisdiction for exercising his power u/s 263 by taking view that the order passed by AO is erroneous and in so far as prejudicial to the interest of justice. - Facts remained that the ld. PCIT passed the impugned order without considering various pleas of the assessee raised in its reply. - Matter restored back - AT
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