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...
Documentary evidence of allotment, continuity of shareholding and transfer deeds was treated as sufficient to prove that the shares sold were bonus shares held by the assessee. On that factual basis, the sale proceeds were not regarded as unexplained cash credit and were not taxed as income from other sources, despite discrepancies in the memorandum of understanding and consideration details. Because the quantum addition fell, the consequential penalty for furnishing inaccurate particulars also failed and was deleted.
Documentary evidence of allotment, continuity of shareholding and transfer deeds was treated as sufficient to prove that the shares sold were bonus shares held by the assessee. On that factual basis, the sale proceeds were not regarded as unexplained cash credit and were not taxed as income from other sources, despite discrepancies in the memorandum of understanding and consideration details. Because the quantum addition fell, the consequential penalty for furnishing inaccurate particulars also failed and was deleted.
Note: It is a system-generated summary and is for quick reference only.
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