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 ...
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
Reassessment - disclouser of information - A parrot-like repetition of the statutory language without any substance would certainly not amount to satisfying the jurisdictional conditions but if coupled with the context is sufficiently capable of conveying the fact that there was failure on the part of the assessee, that should be sufficient compliance with the requirements of section 148(2) of the Act. - HC
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