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...
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
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