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...
Reopening of assessment u/s 147 - Service of the Notice u/s 148 - Over enthusiastically and by way of abundant caution, the notice u/s148 has been sent yet again on 31.07.2019 and this has been received by one 'A.Lakshmi' on 31.07.2019. According to petitioner, there is nobody by that name in that address. However, this is really irrelevant, since service of notice u/s 148 on the petitioner is already been complete even at first instance. - HC
Reopening of assessment u/s 147 - Service of the Notice u/s 148 - Over enthusiastically and by way of abundant caution, the notice u/s148 has been sent yet again on 31.07.2019 and this has been received by one 'A.Lakshmi' on 31.07.2019. According to petitioner, there is nobody by that name in that address. However, this is really irrelevant, since service of notice u/s 148 on the petitioner is already been complete even at first instance. - HC
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