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...
Search and seizure operations conducted by respondent No. 3 on petitioner-Company's sister entity premises, seizing material like sales registers, accounts books, and data. Petitioner unable to file detailed reply to Show Cause Notice due to seized documents. Court accepted petitioner's explanation, set aside impugned orders, and remanded matter to respondent No. 2 for reconsideration of reply stage, directing respondent No. 3 to provide seized documents' copies to petitioner-Company.
Search and seizure operations conducted by respondent No. 3 on petitioner-Company's sister entity premises, seizing material like sales registers, accounts books, and data. Petitioner unable to file detailed reply to Show Cause Notice due to seized documents. Court accepted petitioner's explanation, set aside impugned orders, and remanded matter to respondent No. 2 for reconsideration of reply stage, directing respondent No. 3 to provide seized documents' copies to petitioner-Company.
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