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...
Recalling of order - Matter was heard ex-parte - it is opined that since the Revenue has already acted upon the impugned final order and has already taken steps to implement the same there seems no justification nor even scope to recall such a final order especially when the proceedings were well in the notice of the applicant since first round of litigation in the impugned matter. - There are no justification in the prayer of the appellant - AT
Recalling of order - Matter was heard ex-parte - it is opined that since the Revenue has already acted upon the impugned final order and has already taken steps to implement the same there seems no justification nor even scope to recall such a final order especially when the proceedings were well in the notice of the applicant since first round of litigation in the impugned matter. - There are no justification in the prayer of the appellant - AT
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