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...
Rectification u/s 154 - refund of taxes paid in foreign country - The High court noted that the Hon'ble Apex Court had expressly overruled the AAR order in a previous case involving the petitioner, which entitled the petitioner to seek rectification and refund of taxes paid under protest. - The court emphasized the importance of the circular dated 17.11.1971, which allows rectification of returns based on the interpretation of law by the Hon'ble Apex Court. - Consequently, the court allowed the petition, set aside the impugned order, and directed the concerned respondents to refund the taxes paid by the petitioner along with applicable interest.
Rectification u/s 154 - refund of taxes paid in foreign country - The High court noted that the Hon'ble Apex Court had expressly overruled the AAR order in a previous case involving the petitioner, which entitled the petitioner to seek rectification and refund of taxes paid under protest. - The court emphasized the importance of the circular dated 17.11.1971, which allows rectification of returns based on the interpretation of law by the Hon'ble Apex Court. - Consequently, the court allowed the petition, set aside the impugned order, and directed the concerned respondents to refund the taxes paid by the petitioner along with applicable interest.
Note: It is a system-generated summary and is for quick reference only.