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 ...
Focus Product Scheme incentive received by the assessee was treated as a capital receipt, because the Tribunal followed its co-ordinate bench decision in the assessee's own case for the immediately succeeding year on identical facts. The Assessing Officer was directed to allow the claim accordingly. The Tribunal also noted that the assessee's additional claim ought to have been examined in appeal, and therefore granted relief by accepting the incentive as capital in nature.
Focus Product Scheme incentive received by the assessee was treated as a capital receipt, because the Tribunal followed its co-ordinate bench decision in the assessee's own case for the immediately succeeding year on identical facts. The Assessing Officer was directed to allow the claim accordingly. The Tribunal also noted that the assessee's additional claim ought to have been examined in appeal, and therefore granted relief by accepting the incentive as capital in nature.
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