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 ...
Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
Numerical entries in seized records may be read by appending zeros only where the interpretation is supported by the nature of the entries and surrounding material. The High Court restored the addition based on the Commissioner (Appeals)' reasoned interpretation of pages 4 and 5 of Annexure B-3, holding that the Tribunal could not append a single zero after rejecting larger multipliers without reasons. Additions for unexplained investment and undisclosed profit from other rough-diamond entries were deleted because those transactions had already been considered for taxation in another entity's assessment and the assessee lacked financial capacity to conduct the business independently. Revenue appeals were partly allowed.
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