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 ...
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
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