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 ...
Reopening under section 147 failed because the Assessing Officer merely reproduced Investigation Wing material and third-party statements without independent enquiry or a live nexus to the assessee's alleged escaped income; the notice under section 148 and the reassessment were therefore bad in law. On the addition under section 68, the assessee produced ledger accounts, bank statements, confirmations, returns, financial statements and related memoranda showing advances for land procurement and project development, with the funds routed through banking channels and later repaid. The Tribunal held that these primary documents established identity, creditworthiness and genuineness, and that untested third-party statements could not displace them without specific enquiry. The addition was deleted.
Reopening under section 147 failed because the Assessing Officer merely reproduced Investigation Wing material and third-party statements without independent enquiry or a live nexus to the assessee's alleged escaped income; the notice under section 148 and the reassessment were therefore bad in law. On the addition under section 68, the assessee produced ledger accounts, bank statements, confirmations, returns, financial statements and related memoranda showing advances for land procurement and project development, with the funds routed through banking channels and later repaid. The Tribunal held that these primary documents established identity, creditworthiness and genuineness, and that untested third-party statements could not displace them without specific enquiry. The addition was deleted.
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