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 ...
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
Where scrutiny assessment is completed through the e-proceedings mechanism, the prescribed procedure requires the Assessing Officer to sign the assessment order digitally. Because the assessment order in this case was admittedly passed through e-proceedings but was only manually signed, it did not conform to the binding procedure and the defect vitiated the assessment. The additional legal ground was therefore admitted, the assessment was quashed, and the remaining grounds were treated as academic.
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