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...
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
AO exceeded jurisdiction by disallowing claim of brought forward unabsorbed depreciation through rectification u/s 154, as CIT(A) did not direct such disallowance. CIT(A) order attained finality on this issue. Post CIT(A) order, AO cannot rectify u/s 154 in absence of mistake apparent from record. CIT(A) order upheld, Revenue's appeal dismissed.
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