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 ...
Non-deduction of TDS u/s 194H r.w.s. 40(a)(ia) - nature of discount - Some services should be provided by the person or any other services in the course of buying and selling of goods - since there was no relationship between the assessee and its customers as of principal and agents, the amount of discount cannot be termed as commission - No TDS liability - AT
Non-deduction of TDS u/s 194H r.w.s. 40(a)(ia) - nature of discount - Some services should be provided by the person or any other services in the course of buying and selling of goods - since there was no relationship between the assessee and its customers as of principal and agents, the amount of discount cannot be termed as commission - No TDS liability - AT
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