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...
Addition of ex-gratia payment by assessee-bank - The view of the AO that the payment is made in lieu of the dividend or distribution of profit cannot be accepted because employees are not entitled to share in the profits as well as distribution of the dividend.
Addition of ex-gratia payment by assessee-bank - The view of the AO that the payment is made in lieu of the dividend or distribution of profit cannot be accepted because employees are not entitled to share in the profits as well as distribution of the dividend.
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