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 ...
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Relevant date for filing of Refund - It is settled that even if the refund claim is filed well within the time and the same is returned for want of clarification or documents and the claim was resubmitted, the date of filing the refund application is taken as the date of first filing the refund claim and not the date on which the claim was resubmitted. - AT
Relevant date for filing of Refund - It is settled that even if the refund claim is filed well within the time and the same is returned for want of clarification or documents and the claim was resubmitted, the date of filing the refund application is taken as the date of first filing the refund claim and not the date on which the claim was resubmitted. - AT
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