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...
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
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