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 ...
Unexplained bank credits require credit-wise verification; a difference between aggregate bank deposits and GST-reported turnover does not, by itself, establish unexplained money. The taxpayer must establish the nature and source of credits, while the assessment must examine sales receipts, inter-bank transfers, contra entries, redeposits, expenses and disclosed business results. Business-profit estimation must rely on the nature of trade, prior or later results, comparable cases or other relevant material rather than an arbitrary rate. Consequential penalty requires reconsideration after fresh quantum assessment. A Form 26AS entry showing tax collection on a motor vehicle transaction requires verification of whether the transaction was a purchase or sale before taxing any short-term capital gain.
Unexplained bank credits require credit-wise verification; a difference between aggregate bank deposits and GST-reported turnover does not, by itself, establish unexplained money. The taxpayer must establish the nature and source of credits, while the assessment must examine sales receipts, inter-bank transfers, contra entries, redeposits, expenses and disclosed business results. Business-profit estimation must rely on the nature of trade, prior or later results, comparable cases or other relevant material rather than an arbitrary rate. Consequential penalty requires reconsideration after fresh quantum assessment. A Form 26AS entry showing tax collection on a motor vehicle transaction requires verification of whether the transaction was a purchase or sale before taxing any short-term capital gain.
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