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...
Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
Validity of reopening of assessment - clandestine and unaccounted sales - The High Court reviewed a petition challenging the rejection of objections to a notice for reassessment under the Income Tax Act. The petitioner argued that the reassessment was based on a change of opinion rather than a mistake. The court examined the assessment procedure and found that the reasons for reopening the assessment did not indicate the discovery of new material but rather a potential change of opinion. - Consequently, the court quashed the impugned order and notice, ruling in favor of the petitioner.
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