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...
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
Protective addition failed where the cash allegedly routed for gold purchase was owned up by other persons and the assessee was shown only as a facilitator, so the cash could not be taxed in his hands. Commission income was also deleted in the Prateek Bansal gold transaction because Bansal admitted the transaction and its profit, and there was no material for a separate commission to the assessee. For the seized 2 kg gold, ownership remained unclear; verification from the Enforcement Directorate was directed before deciding whether it was assessable as commission in the assessee's hands or in the company's hands.
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