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 ...
Disallowance u/s 36[1](viii] - no reserve was created - appellant submits that the appellant may be permitted now to create such reserve - such non-creation of special reserve by the assessee cannot be made good by creating any reserve on a later date - AT
Disallowance u/s 36[1](viii] - no reserve was created - appellant submits that the appellant may be permitted now to create such reserve - such non-creation of special reserve by the assessee cannot be made good by creating any reserve on a later date - AT
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