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 ...
Validity of assessment order - difference of turnover between P & L account and balance sheet, on the one hand, and GSTR-9, on the other - The High Court Noted that the assessing officer accepted explanations for certain defects raised by the petitioner but failed to apply proper reasoning in addressing others. Identified jurisdictional errors in the determination of tax liabilities, particularly regarding turnover differences and transitional credit. - Matter restored back to AO for reconsideration.
Validity of assessment order - difference of turnover between P & L account and balance sheet, on the one hand, and GSTR-9, on the other - The High Court Noted that the assessing officer accepted explanations for certain defects raised by the petitioner but failed to apply proper reasoning in addressing others. Identified jurisdictional errors in the determination of tax liabilities, particularly regarding turnover differences and transitional credit. - Matter restored back to AO for reconsideration.
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