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...
Condonation of Delay in filing the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
Condonation of Delay in filing the returns of income seeking refund - delay due to date of ruling of the AAR - genuine hardship - The delay in filing tax returns for AYs 2012-13 and 2013-14 by the petitioner was condoned under Section 119(2)(b) of the Income Tax Act, subject to payment of costs, due to genuine hardship. The assessing officer was directed to process the returns after compliance with the conditional order. - HC
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