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 ...
Rule 11UA leaves the assessee free to choose the DCF method for valuing unquoted shares, and the Assessing Officer may test the report and assumptions but cannot replace that method with NAV merely of his own preference; on the facts noted, the independent investor's participation and response to notices supported the genuineness of the transaction, so the share-premium addition under section 56(2)(viib) was unsustainable. On section 14A, no disallowance could be made because no exempt income was earned during the year, and the Finance Act, 2022 amendment was held prospective, so it did not apply to AY 2018-19.
Rule 11UA leaves the assessee free to choose the DCF method for valuing unquoted shares, and the Assessing Officer may test the report and assumptions but cannot replace that method with NAV merely of his own preference; on the facts noted, the independent investor's participation and response to notices supported the genuineness of the transaction, so the share-premium addition under section 56(2)(viib) was unsustainable. On section 14A, no disallowance could be made because no exempt income was earned during the year, and the Finance Act, 2022 amendment was held prospective, so it did not apply to AY 2018-19.
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