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...
Recovery notice - Validity of assessment orders - The High court observed that while personal hearings were offered to the petitioner, it was evident that the petitioner was not heard during the assessment process. Additionally, the assessing officer relied on internet-based information without affording the petitioner an opportunity to challenge or provide contrary evidence. Consequently, the court found the lack of proper opportunity for the petitioner to be heard as a procedural irregularity, warranting interference. - Matter restored back for fresh adjudication.
Recovery notice - Validity of assessment orders - The High court observed that while personal hearings were offered to the petitioner, it was evident that the petitioner was not heard during the assessment process. Additionally, the assessing officer relied on internet-based information without affording the petitioner an opportunity to challenge or provide contrary evidence. Consequently, the court found the lack of proper opportunity for the petitioner to be heard as a procedural irregularity, warranting interference. - Matter restored back for fresh adjudication.
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