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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WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
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