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 ...
Scope of the Adjustment made by the CPC u/s 143(1) when scrutiny assessment made u/s 143(3) - Considering the facts that the case of the assessee was subsequently taken up for scrutiny assessment and subsequent assessment order u/s 143(3) has been passed on 24.02.2021, we find that the order of processing u/s 143(1) stands merged with the scrutiny assessment order passed u/s 143(3) and therefore, the appeal proceedings against the processing and adjustment made by the CPC, becomes infructuous - AT
Scope of the Adjustment made by the CPC u/s 143(1) when scrutiny assessment made u/s 143(3) - Considering the facts that the case of the assessee was subsequently taken up for scrutiny assessment and subsequent assessment order u/s 143(3) has been passed on 24.02.2021, we find that the order of processing u/s 143(1) stands merged with the scrutiny assessment order passed u/s 143(3) and therefore, the appeal proceedings against the processing and adjustment made by the CPC, becomes infructuous - AT
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