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...
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The Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
The Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
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