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 ...
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
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