Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises.
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