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...
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
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