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 ...
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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