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 ...
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
Interest on placements between an Indian branch and its head office or overseas branches was treated as payment to self and not taxable income; the treaty's separate-entity fiction was confined to profit attribution, and interest from other overseas banks also failed because the statutory condition requiring the non-resident payer's borrowing for business in India was not shown. Broken period interest paid on SLR securities held as stock-in-trade was deductible as revenue expenditure. Bad debt deduction failed because the debtors' accounts were not reduced and the amount remained on the liability side. Club membership fees for employees were allowable. Interest on a refund could not be recovered under the shortfall-in-advance-tax provision, and section 14A did not apply because the receipt itself was not income.
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