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...
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
Reopening assessment u/s 148 upheld based on specific information from DDIT (Inv) about transactions with M/s Vishnu Trading Co, providing reasonable belief of escaped income. Addition u/s 68 as unexplained cash credits deleted as books not rejected, quantitative details provided, and lack of evidence of accommodation entries. Cross-examination opportunity denied, violating natural justice principles. Transactions with M/s Edelweiss Commodities misunderstood. Consequential deletion of taxation u/s 115BBE, interest u/ss 234A, 234B, 234C, 234D, and penalty u/s 271(1)(c).
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