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 ...
Interest-free advance to subsidiary company - Nexus has been established by the assessee and when there is no interest burden on the assessee by virtue of the loan advanced to its subsidiary no such interest income can be attributed in the hands of the assessee - AT
Interest-free advance to subsidiary company - Nexus has been established by the assessee and when there is no interest burden on the assessee by virtue of the loan advanced to its subsidiary no such interest income can be attributed in the hands of the assessee - AT
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