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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the due date for filing the annual return has been reached. Applying an earlier Division Bench view, the HC held that the impugned assessment, framed by one order for multiple financial years, was unsustainable and set it aside. The matter was remitted with liberty to commence fresh proceedings separately for each assessment year, and the intervening period was excluded for limitation purposes. All other grounds raised by the petitioner were left open.
A single show-cause notice or composite assessment order cannot validly cover more than one tax period once the due date for filing the annual return has been reached. Applying an earlier Division Bench view, the HC held that the impugned assessment, framed by one order for multiple financial years, was unsustainable and set it aside. The matter was remitted with liberty to commence fresh proceedings separately for each assessment year, and the intervening period was excluded for limitation purposes. All other grounds raised by the petitioner were left open.
Note: It is a system-generated summary and is for quick reference only.