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...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Penalty u/s 271(1)(c) - non-compliance of notice issues - if the quantum proceedings itself are declared to be bad in law and quashed , then any non compliance on the part of the assessee to respond to notice issued u/s 142(1) during such proceedings which are held to be void ab inito and proceedings without jurisdiction , will not give rise to any cause of action for validly initiating penalty proceedings u/s 271(1)(b) for non compliance of notice issued u/s 142(1) during such proceedings - AT
Penalty u/s 271(1)(c) - non-compliance of notice issues - if the quantum proceedings itself are declared to be bad in law and quashed , then any non compliance on the part of the assessee to respond to notice issued u/s 142(1) during such proceedings which are held to be void ab inito and proceedings without jurisdiction , will not give rise to any cause of action for validly initiating penalty proceedings u/s 271(1)(b) for non compliance of notice issued u/s 142(1) during such proceedings - AT
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