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 ...
Assessment u/s 144A - Power of JCIT to issue directions in certain cases - Directions to be exercised by the Joint Commissioner under Section 144(A) is merely intended to guide the Assessing Officer to complete the assessment and only such directions are binding on an Assessing Officer. Since directions contained in the impugned order passed by the Joint Commissioner was prejudicial to the petitioner and to complete the assessment in a particular manner, petitioner should have been called for hearing by the second respondent Joint Commissioner. - The assessment order quashed - HC
Assessment u/s 144A - Power of JCIT to issue directions in certain cases - Directions to be exercised by the Joint Commissioner under Section 144(A) is merely intended to guide the Assessing Officer to complete the assessment and only such directions are binding on an Assessing Officer. Since directions contained in the impugned order passed by the Joint Commissioner was prejudicial to the petitioner and to complete the assessment in a particular manner, petitioner should have been called for hearing by the second respondent Joint Commissioner. - The assessment order quashed - HC
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