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 ...
Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).
Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).
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