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 - notice u/s 148A(b) - the intent behind issuing the notice u/s 148A(b) is to inform the assessee of the allegations against him/her with sufficient particulars so that he/she can put forward his/her defence - AO has been negligent in incorporating the incorrect information and in not admitting the fact that he had committed a mistake while issuing a notice under Section 148A(b) of the Act even at the time of passing the order u/s 148A(d) of the Act. - HC
Reopening of assessment u/s 147 - notice u/s 148A(b) - the intent behind issuing the notice u/s 148A(b) is to inform the assessee of the allegations against him/her with sufficient particulars so that he/she can put forward his/her defence - AO has been negligent in incorporating the incorrect information and in not admitting the fact that he had committed a mistake while issuing a notice under Section 148A(b) of the Act even at the time of passing the order u/s 148A(d) of the Act. - HC
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