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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Assessment order passed without issuing notice u/s 143(2) after considering assessee's return is illegal and liable to be set aside, as non-issuance of Section 143(2) notice is a fatal defect, not curable u/s 292B. Assessee's request to treat return filed u/s 139(1) as response to notice u/s 148 does not cure the defect. Assessment order is unsustainable, appeal allowed.
Assessment order passed without issuing notice u/s 143(2) after considering assessee's return is illegal and liable to be set aside, as non-issuance of Section 143(2) notice is a fatal defect, not curable u/s 292B. Assessee's request to treat return filed u/s 139(1) as response to notice u/s 148 does not cure the defect. Assessment order is unsustainable, appeal allowed.
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