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...
Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
Delay of 294 days in filing Special Leave Petition deemed invalid. Reopening of assessment u/s 143(3) without proper sanction u/s 151(1) from competent authority. Income Tax Officer obtained satisfaction from Additional Commissioner, an authority not covered by Section 151(1). Writ petition under Article 226 maintainable due to non-fulfillment of pre-conditions for exercise of power u/s 148. Application seeking condonation of delay dismissed by Supreme Court due to unsatisfactory explanation, consequently dismissing Special Leave Petition on ground of delay.
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