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...
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
Penalty u/s 271D / 271E - violation of provisions of Sec.269SS and 269T - basis of presumption u/s 132(4A) - Period of limitation - The Tribunal found that the penalty proceedings were not validly initiated due to the lack of satisfaction recorded in the assessment order regarding the violation of provisions of Sec.269SS. - It determined that the delay in moving the proposal for penalty proceedings after the conclusion of assessment proceedings was in violation of the CBDT Circular.
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