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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With effect from conversion, the LLP was a separate legal entity, so municipal and property taxes attributable to the pre-conversion period belonged to the erstwhile private limited company and could not be claimed by the LLP as its own expenditure or loss. The Tribunal therefore sustained the disallowance of the pre-conversion taxes, noting that the assessee's relied-upon provisions did not apply on the facts found and that the earlier company had not filed a return. However, it accepted the alternative claim that income assessed under the head house property must carry the statutory standard deduction and directed the Assessing Officer to allow it.
With effect from conversion, the LLP was a separate legal entity, so municipal and property taxes attributable to the pre-conversion period belonged to the erstwhile private limited company and could not be claimed by the LLP as its own expenditure or loss. The Tribunal therefore sustained the disallowance of the pre-conversion taxes, noting that the assessee's relied-upon provisions did not apply on the facts found and that the earlier company had not filed a return. However, it accepted the alternative claim that income assessed under the head house property must carry the statutory standard deduction and directed the Assessing Officer to allow it.
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