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...
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Rejection of books of account and profit estimation in a redevelopment project is unjustified where the purported comparable operates at a materially different scale and lacks redevelopment-specific costs. Alleged sales below ready-reckoner value require examination against values prevailing on booking dates, not incomplete data. Cash receipts disclosed under the Income Declaration Scheme may be credited where the disclosure relates to parking-slot sales in the sole redevelopment project. Pending approvals and the occupation certificate support revenue recognition under the project-completion method. An addition based solely on a survey statement cannot be sustained without corroborative evidence.
Rejection of books of account and profit estimation in a redevelopment project is unjustified where the purported comparable operates at a materially different scale and lacks redevelopment-specific costs. Alleged sales below ready-reckoner value require examination against values prevailing on booking dates, not incomplete data. Cash receipts disclosed under the Income Declaration Scheme may be credited where the disclosure relates to parking-slot sales in the sole redevelopment project. Pending approvals and the occupation certificate support revenue recognition under the project-completion method. An addition based solely on a survey statement cannot be sustained without corroborative evidence.
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