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...
Section 194Q compliance assessments must address Circular No. 13/2021, which provides guidelines for removing difficulties in applying tax deduction requirements to business purchases. A determination concerning alleged non-deduction that does not examine the circular's relevance cannot be sustained. The assessment must therefore be set aside and reconsidered by the assessing authority in light of the circular and applicable law.
Section 194Q compliance assessments must address Circular No. 13/2021, which provides guidelines for removing difficulties in applying tax deduction requirements to business purchases. A determination concerning alleged non-deduction that does not examine the circular's relevance cannot be sustained. The assessment must therefore be set aside and reconsidered by the assessing authority in light of the circular and applicable law.
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