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...
Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
Club membership and subscription expenditure is deductible where its business purpose and nexus are established; an ad hoc disallowance requires identification of particular personal or non-business payments, resulting in deletion of the club-expense disallowance. Where own funds exceed exempt-income investments and borrowings serve specified business purposes, investments are presumed funded from own funds, eliminating interest disallowance under section 14A. Administrative disallowance must have a rational nexus to, and cannot exceed, exempt income. Internal handover, capitalisation and deployment records can establish that machinery was put to use, supporting depreciation and additional depreciation. Electrical installations integral to manufacturing machinery qualify as plant and machinery for additional depreciation. Both appeals were partly allowed.
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