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 ...
Addition u/s 14A - Expenses incurred for earning dividend income - assessee itself suo moto made the disallowance - recording proper satisfaction - The onus was on AO to reject the assessee’s computations and record a finding, having regard to accounts of the assessee, as to how those computations were not satisfactory - addition deleted
Addition u/s 14A - Expenses incurred for earning dividend income - assessee itself suo moto made the disallowance - recording proper satisfaction - The onus was on AO to reject the assessee’s computations and record a finding, having regard to accounts of the assessee, as to how those computations were not satisfactory - addition deleted
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