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 reassessment where the reopening was founded on a GST cancellation order that had already been reversed in appeal. The Court noted that the appellate GST order found no fraudulent ITC claim, no violation attracting adjudication, and no basis for the cancellation. The income-tax authority also failed to consider that appellate material, despite its direct relevance to the alleged escapement of income. With no independent material beyond the set-aside GST action, the initiation of reassessment was unwarranted. The order under Section 148A(3) and the consequential notice under Section 148 were set aside.
HC quashed reassessment where the reopening was founded on a GST cancellation order that had already been reversed in appeal. The Court noted that the appellate GST order found no fraudulent ITC claim, no violation attracting adjudication, and no basis for the cancellation. The income-tax authority also failed to consider that appellate material, despite its direct relevance to the alleged escapement of income. With no independent material beyond the set-aside GST action, the initiation of reassessment was unwarranted. The order under Section 148A(3) and the consequential notice under Section 148 were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
