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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Validity of assessment order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
Validity of assessment order u/s 143(3) r.w.s 263 - no intimation of DIN for the impugned order - The case of the assessee is that the communication, namely the assessment order is not only without mention of DIN in the body of the order, there is no material on the record mentioning the reason for non-issuance of DIN. Furthermore, the letter of intimation of DIN is also not within fifteen (15) working days of the issuance of the impugned assessment order - AT
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