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...
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Reopening of the assessment U/S 147 - the High Court has quashed the show cause notice on the ground that the AO has accepted the claim of expenditures during scrutiny assessment u/s 143(3) - therefore the income escaping proceeding has been initiated marely on the basis of change of opinion and cannot sustain - the apex court refused to interfere in the decision of at HC - SC
Reopening of the assessment U/S 147 - the High Court has quashed the show cause notice on the ground that the AO has accepted the claim of expenditures during scrutiny assessment u/s 143(3) - therefore the income escaping proceeding has been initiated marely on the basis of change of opinion and cannot sustain - the apex court refused to interfere in the decision of at HC - SC
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