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...
Limit limit to pass order u/s. 201(1)/201(1A) - default for non-deduction of tax at source (TDS) - A subsequent amendment to the provision cannot give a new lease of life to the time limit which has already exhausted. Hence, for the years under consideration, it is only the sub-section (3) as amended by Finance Act, 2012 with retrospective effect from 01-04-2010, which shall prevail. Resultantly, the orders passed by the AO beyond the stipulated time limit are time barred and hence quashed. - AT
Limit limit to pass order u/s. 201(1)/201(1A) - default for non-deduction of tax at source (TDS) - A subsequent amendment to the provision cannot give a new lease of life to the time limit which has already exhausted. Hence, for the years under consideration, it is only the sub-section (3) as amended by Finance Act, 2012 with retrospective effect from 01-04-2010, which shall prevail. Resultantly, the orders passed by the AO beyond the stipulated time limit are time barred and hence quashed. - AT
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