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...
Disallowance of key man insurance premium paid - it is not known how the payment of ₹ 10 lakhs towards premium is going to protect the assessee-company from adverse financial effects in case of unexpected death of the Managing Director. When the assessee-company is not eligible to make a claim since the keyman insurance policy holder is holding more than 51% of the shares in the company, this Tribunal is of the considered opinion that such a expenditure was not for business purposes. - AT
Disallowance of key man insurance premium paid - it is not known how the payment of ₹ 10 lakhs towards premium is going to protect the assessee-company from adverse financial effects in case of unexpected death of the Managing Director. When the assessee-company is not eligible to make a claim since the keyman insurance policy holder is holding more than 51% of the shares in the company, this Tribunal is of the considered opinion that such a expenditure was not for business purposes. - AT
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