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 ...
Whether transfer of shares by the assessee is transfer of a capital asset within the meaning of Section 2(14) of the Act or a transfer of business that falls within the ambit of Section 28(va) of the Act - decided against the assessee - HC
Whether transfer of shares by the assessee is transfer of a capital asset within the meaning of Section 2(14) of the Act or a transfer of business that falls within the ambit of Section 28(va) of the Act - decided against the assessee - HC
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