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...
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
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