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 ...
Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
Note: It is a system-generated summary and is for quick reference only.
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