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 ...
Rectification of mistake u/s 154 - limited scrutiny of “Agricultural Income” - The High Court deliberated on the challenge to an Impugned Notice issued u/s 154 - It examined the contentions of both parties regarding the jurisdiction of the Assessing Officer and the scope of rectification u/s 154. Finding that certain issues raised in the notice were not addressed in the original Assessment Order, the Court affirmed the jurisdiction of the Assessing Officer to rectify such errors. It emphasized that the power to rectify extends to mistakes of fact or law apparent from the record. Ultimately, the Court dismissed the writ petition, upholding the validity of the Impugned Notice and allowing for further proceedings.
Rectification of mistake u/s 154 - limited scrutiny of “Agricultural Income” - The High Court deliberated on the challenge to an Impugned Notice issued u/s 154 - It examined the contentions of both parties regarding the jurisdiction of the Assessing Officer and the scope of rectification u/s 154. Finding that certain issues raised in the notice were not addressed in the original Assessment Order, the Court affirmed the jurisdiction of the Assessing Officer to rectify such errors. It emphasized that the power to rectify extends to mistakes of fact or law apparent from the record. Ultimately, the Court dismissed the writ petition, upholding the validity of the Impugned Notice and allowing for further proceedings.
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