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...
Adjustment of a refund against a disputed demand during pendency of statutory remedies was held unsustainable. Following coordinate Bench rulings, the HC quashed the refund adjustment, directed release of the refund with statutory interest, and restrained coercive recovery until the stay application is decided. The Court also requested expeditious disposal of the pending appeal before the CIT(A), and did not examine the merits of the underlying assessment dispute.
Adjustment of a refund against a disputed demand during pendency of statutory remedies was held unsustainable. Following coordinate Bench rulings, the HC quashed the refund adjustment, directed release of the refund with statutory interest, and restrained coercive recovery until the stay application is decided. The Court also requested expeditious disposal of the pending appeal before the CIT(A), and did not examine the merits of the underlying assessment dispute.
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