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 ...
Profits in lieu of salary - chargeable to tax u/s 17(3) or section 28(va) - appellant was not an employee - compensation attributable to a negative/restrictive covenant is a capital receipt. - as the sum received by the appellant does not fall within the ambit of section 28(va), and being a capital receipt is not taxable - AT
Profits in lieu of salary - chargeable to tax u/s 17(3) or section 28(va) - appellant was not an employee - compensation attributable to a negative/restrictive covenant is a capital receipt. - as the sum received by the appellant does not fall within the ambit of section 28(va), and being a capital receipt is not taxable - AT
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