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 held that a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
HC held that a refund order was unsustainable where it granted refund but did not consider or decide the petitioners' separate claim for accrued interest. The absence of any finding or reason on the interest component showed non-application of mind and failure to pass a reasoned order on an independent claim. The Court did not decide entitlement to interest on merits; it remitted the interest claim for fresh consideration and adjudication in accordance with law, after granting a personal hearing and leaving all contentions open.
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