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...
Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a greater latitude to reopen the assessment. - AO had sufficient material at his command to form a belief that the income chargeable to tax has escaped assessment. There is a clear link between the information available with the assessing officer and his formation of belief that the income chargeable to tax has escaped assessment. - HC
Reopening of assessment u/s 147 - concept of change of opinion - In cases where the return of an assessee is accepted without scrutiny, the assessing officer enjoys a greater latitude to reopen the assessment. - AO had sufficient material at his command to form a belief that the income chargeable to tax has escaped assessment. There is a clear link between the information available with the assessing officer and his formation of belief that the income chargeable to tax has escaped assessment. - HC
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