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...
Reopening of concluded assessments - Under Rule 26-A of the OST Rules, a registered dealer is expected to preserve books of account and other documents including bills, credit and cash memoranda, invoices and vouchers, etc. relating to the business of any year for a period of three years thereafter or for a period of 12 months after finalization of the order of assessment or penalty in appeal, revision or reference for the year to which it relates, whichever is later - As far as the present case is concerned, even if the aforementioned periods of limitation have been crossed, there is no legal basis for the Department in the present case to have sought to re-compute the tax, surcharge and interest payable by the Petitioner for the aforementioned periods. - HC
Reopening of concluded assessments - Under Rule 26-A of the OST Rules, a registered dealer is expected to preserve books of account and other documents including bills, credit and cash memoranda, invoices and vouchers, etc. relating to the business of any year for a period of three years thereafter or for a period of 12 months after finalization of the order of assessment or penalty in appeal, revision or reference for the year to which it relates, whichever is later - As far as the present case is concerned, even if the aforementioned periods of limitation have been crossed, there is no legal basis for the Department in the present case to have sought to re-compute the tax, surcharge and interest payable by the Petitioner for the aforementioned periods. - HC
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