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 ...
Debatable employees' PF/ESI contribution claims could not be disallowed through summary adjustment where, on the intimation date, jurisdictional High Court authority supported allowability of payments made before the return-filing due date. Retention of that adjustment in scrutiny without independent examination remained challengeable in appeal, and the AY 2018-19 disallowance was deleted. For exempt-income expenditure, only investments that actually yielded exempt income during the relevant year could be considered under section 14A and Rule 8D; no additional disallowance survived beyond the voluntary amount, and the related book-profit adjustment was also deleted for AY 2018-19. Charitable-contribution deductions were remitted solely to verify payment receipts and genuineness.
Debatable employees' PF/ESI contribution claims could not be disallowed through summary adjustment where, on the intimation date, jurisdictional High Court authority supported allowability of payments made before the return-filing due date. Retention of that adjustment in scrutiny without independent examination remained challengeable in appeal, and the AY 2018-19 disallowance was deleted. For exempt-income expenditure, only investments that actually yielded exempt income during the relevant year could be considered under section 14A and Rule 8D; no additional disallowance survived beyond the voluntary amount, and the related book-profit adjustment was also deleted for AY 2018-19. Charitable-contribution deductions were remitted solely to verify payment receipts and genuineness.
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