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...
Ex parte tax adjudication was set aside where the assessee had not been given a reasonable opportunity of hearing and the order was not reasoned. The HC followed earlier coordinate Bench rulings, quashed the impugned orders, and remitted the matter for fresh adjudication by a proper officer other than the original officer from the stage of reply to the show-cause notice. Liberty was granted to file additional material, and the authority was directed to afford a reasonable hearing and pass a speaking order.
Ex parte tax adjudication was set aside where the assessee had not been given a reasonable opportunity of hearing and the order was not reasoned. The HC followed earlier coordinate Bench rulings, quashed the impugned orders, and remitted the matter for fresh adjudication by a proper officer other than the original officer from the stage of reply to the show-cause notice. Liberty was granted to file additional material, and the authority was directed to afford a reasonable hearing and pass a speaking order.
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