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 ...
Low household withdrawals were treated as unjustified where the assessee showed substantially lower withdrawals than in the preceding year and produced no evidence that the spouse met household expenses, so the Revenue's estimation was upheld. Year-end trade and expense creditors were not assessable as unexplained cash credits under section 68 because the assessment accepted the transaction credits but rejected only the unpaid balances without reason, and the outstanding amounts were later paid through banking channels. Freight expenditure was disallowed under section 40(a)(ia) because tax had not been deducted at source and the transporters' declarations under section 194C(6) were incomplete and appeared afterthoughts, so the disallowance was sustained.
Low household withdrawals were treated as unjustified where the assessee showed substantially lower withdrawals than in the preceding year and produced no evidence that the spouse met household expenses, so the Revenue's estimation was upheld. Year-end trade and expense creditors were not assessable as unexplained cash credits under section 68 because the assessment accepted the transaction credits but rejected only the unpaid balances without reason, and the outstanding amounts were later paid through banking channels. Freight expenditure was disallowed under section 40(a)(ia) because tax had not been deducted at source and the transporters' declarations under section 194C(6) were incomplete and appeared afterthoughts, so the disallowance was sustained.
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