Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Reopening of assessment u/s 147 - Income accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC
Reopening of assessment u/s 147 - Income accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC
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