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 ...
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
An appellate authority dealing with one assessment year cannot issue directions affecting reopening for earlier years, because its jurisdiction is confined to the year under appeal. The Tribunal held that the Commissioner (Appeals) went beyond the scope of the appeal by directing reopening of earlier assessment years, so that direction was beyond competence and had to be expunged. The separate validity of reopening under section 150 was left unexamined, as the matter was resolved on lack of appellate jurisdiction alone.
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