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 ...
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
Transfer-pricing adjustment for intra-group management, sales and support services was deleted after the Tribunal applied a co-ordinate Bench decision to the material facts. The adjustment had determined the arm's length price of those services at nil. The appeal was allowed on this issue, while the remaining grounds were left open.
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