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...
Transportation expenditure incurred before contract work was handed to a sub-contractor remained deductible where a memorandum recorded the parties' prior understanding that the assessee would bear that cost. The later execution of the definitive sub-contract did not displace that arrangement, and no duplicate claim by the sub-contractor was alleged; the disallowance was therefore deleted. Labour cess and copy charges deducted from the assessee's contract bills under tender terms were also deductible because the assessee incurred and bore them, their genuineness was undisputed, and the sub-contractor had not claimed them. The related disallowance of sublet expenses was deleted.
Transportation expenditure incurred before contract work was handed to a sub-contractor remained deductible where a memorandum recorded the parties' prior understanding that the assessee would bear that cost. The later execution of the definitive sub-contract did not displace that arrangement, and no duplicate claim by the sub-contractor was alleged; the disallowance was therefore deleted. Labour cess and copy charges deducted from the assessee's contract bills under tender terms were also deductible because the assessee incurred and bore them, their genuineness was undisputed, and the sub-contractor had not claimed them. The related disallowance of sublet expenses was deleted.
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