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...
HC quashed assessment order for 2018-19 due to violation of natural justice principles under Section 169. Authority failed to serve proper notice seeking explanation regarding alleged defects. Following precedent established in prior cases, Court affirmed mandatory requirement of notice delivery either in person, registered post, or registered email. Only upon impracticability of these methods can alternative publication through portal/newspaper be considered. Assessment order converted to show cause notice, allowing petitioner opportunity to respond. Decision upholds fundamental right to be heard before adverse action, reinforcing procedural safeguards in tax assessment proceedings.
HC quashed assessment order for 2018-19 due to violation of natural justice principles under Section 169. Authority failed to serve proper notice seeking explanation regarding alleged defects. Following precedent established in prior cases, Court affirmed mandatory requirement of notice delivery either in person, registered post, or registered email. Only upon impracticability of these methods can alternative publication through portal/newspaper be considered. Assessment order converted to show cause notice, allowing petitioner opportunity to respond. Decision upholds fundamental right to be heard before adverse action, reinforcing procedural safeguards in tax assessment proceedings.
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