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 ...
Explanation of the source of investment - there being no income of the company at the relevant period when unaccounted investment was made, the same has to be assessed in the hands of the assessee - HC
Explanation of the source of investment - there being no income of the company at the relevant period when unaccounted investment was made, the same has to be assessed in the hands of the assessee - HC
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