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 ...
Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
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