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...
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Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
Non-filing of returns by some suppliers, without further enquiry or contrary material, was held insufficient to reject recorded purchases where payments were through banking channels and sales were accepted; the ad hoc gross profit addition on disputed purchases was deleted. For unaccounted sales, only the profit element was treated as taxable, and the income was estimated on a net profit basis at 2% rather than by taxing the entire sales. Alleged entry-fee receipts based on extrapolation from a limited period were curtailed, with only 25% of the estimated addition sustained. Separate addition for unexplained expenditure was deleted on telescoping, as the sustained undisclosed income was treated as available to meet that expenditure.
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