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...
Penalty under the Interest Tax Act required concealment of chargeable interest or furnishing of inaccurate particulars; where the assessee's earlier non-filing was found bona fide, the interest details were already available on record, and the returns filed in response to notice were accepted without addition, penalty was not leviable. The Court also noted that the deeming principle in Explanation 3 to section 271(1)(c) of the Income-tax Act could not be imported into penalty proceedings under the Interest Tax Act. On these concurrent findings, deletion of the penalty was upheld and the Revenue's appeals failed.
Penalty under the Interest Tax Act required concealment of chargeable interest or furnishing of inaccurate particulars; where the assessee's earlier non-filing was found bona fide, the interest details were already available on record, and the returns filed in response to notice were accepted without addition, penalty was not leviable. The Court also noted that the deeming principle in Explanation 3 to section 271(1)(c) of the Income-tax Act could not be imported into penalty proceedings under the Interest Tax Act. On these concurrent findings, deletion of the penalty was upheld and the Revenue's appeals failed.
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