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...
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
In closely held companies, share capital credits require proof of identity, creditworthiness and genuineness; mere documentary filing is not enough where enquiries create doubts, and the share capital and premium addition was restored. Alleged commission on accommodation entries could not be sustained on surmise alone, so relief was granted on that item. Sundry creditor transactions required fresh verification because unresolved mismatches and bona fides concerns remained, so the issue was remanded for enquiry. On gross profit, complete deletion was rejected, but the best-judgment estimate was moderated and the rate was directed to be recomputed at 7%.
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