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 ...
Requirement to furnish Permanent Account Number - TDS @20% - section 206AA of the Act cannot be invoked by the AO to insist on the tax deduction @ 20%, having regard to the overriding nature of the provisions of section 90(2) because the provisions of the DTAAs was more beneficial - AT
Requirement to furnish Permanent Account Number - TDS @20% - section 206AA of the Act cannot be invoked by the AO to insist on the tax deduction @ 20%, having regard to the overriding nature of the provisions of section 90(2) because the provisions of the DTAAs was more beneficial - AT
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