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...
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
Order u/s 119(2)(b) of the Act rejecting the application for waiver of time limit for filing of the return - claim in the refund on account of the tax deducted at source from the income of late father - The Court noted that the PCIT's rejection was contrary to established legal principles. Referring to precedents, the Court emphasized the need for a liberal interpretation of "genuine hardship" and justice-oriented approach in such matters. The High Court held that the petition succeeds and is accordingly allowed.
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