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 of cash payments u/s 40A(3) - making additions by invoking the provisions of section 40A(3) of the Act amounts to double additions which is not permissible under the law. There exists a business expediency in making the cash payments towards purchase of goods. The assessee was obliged to make the cash payments required by the suppliers - AT
Disallowance of cash payments u/s 40A(3) - making additions by invoking the provisions of section 40A(3) of the Act amounts to double additions which is not permissible under the law. There exists a business expediency in making the cash payments towards purchase of goods. The assessee was obliged to make the cash payments required by the suppliers - AT
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