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 - Reasons to believe - surrender of the pension policy - The policy in question was assigned to third party and said assignee had received the surrender value. The petitioner was sought to be taxed by way of reopening, the amount, which was as such received by third party. This was clearly not permissible in law - the petition of the petitioner is entitled to succeed. - HC
Reopening of assessment u/s 147 - Reasons to believe - surrender of the pension policy - The policy in question was assigned to third party and said assignee had received the surrender value. The petitioner was sought to be taxed by way of reopening, the amount, which was as such received by third party. This was clearly not permissible in law - the petition of the petitioner is entitled to succeed. - HC
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