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...
Impugned proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
Impugned proceedings challenged for exceeding scope of show cause notice, non-consideration of submissions during investigation and payments made, gross non-application of mind to material facts, and violation of natural justice principles. Impugned order set aside, petitioner directed to deposit 25% of disputed tax within two weeks, tax already paid adjusted towards deposit. Impugned assessment order treated as show cause notice, petitioner to submit objections with supporting documents within four weeks. Petition disposed of.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
