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...
Exemption from Pre-deposit - The petitioner argued that their request for exemption from pre-deposit was wrongly rejected, and they challenged the jurisdiction of imposing liability. The court, after considering the submissions and relevant provisions of the Income Tax Act, directed the CIT (Appeals) to decide the appeal expeditiously without insisting on the pre-deposit. The court emphasized compliance with Notification and Instruction No. 1914 issued under Section 220 of the Income Tax Act. However, the judgment did not delve into the specifics of the jurisdictional challenge raised by the petitioner.
Exemption from Pre-deposit - The petitioner argued that their request for exemption from pre-deposit was wrongly rejected, and they challenged the jurisdiction of imposing liability. The court, after considering the submissions and relevant provisions of the Income Tax Act, directed the CIT (Appeals) to decide the appeal expeditiously without insisting on the pre-deposit. The court emphasized compliance with Notification and Instruction No. 1914 issued under Section 220 of the Income Tax Act. However, the judgment did not delve into the specifics of the jurisdictional challenge raised by the petitioner.
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