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...
Validity of draft assessment order and final assessment order as barred by limitation u/s 153(2A) - Scope of the word “received” - Tribunal held the draft assessment order and final assessment order passed by the AO are barred by limitation u/s 153(2A) - The High Court observed that, ITAT has while passing the orders impugned before us proceeded on the basis of the principles enunciated in the aforenoted two decisions of the High Court. - The HC dismissed the revenue's appeal.
Validity of draft assessment order and final assessment order as barred by limitation u/s 153(2A) - Scope of the word “received” - Tribunal held the draft assessment order and final assessment order passed by the AO are barred by limitation u/s 153(2A) - The High Court observed that, ITAT has while passing the orders impugned before us proceeded on the basis of the principles enunciated in the aforenoted two decisions of the High Court. - The HC dismissed the revenue's appeal.
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