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...
Revision u/s 263 - estimation of income - when the income assessed by the AO was far more than the income returned by the assessee and all the investments made by the assessee stood explained - estimation of income adopted by the AO, being one of the recognized methods of determination of income, could not be found fault - not find any perversity in the finding - no substantial questions of law
Revision u/s 263 - estimation of income - when the income assessed by the AO was far more than the income returned by the assessee and all the investments made by the assessee stood explained - estimation of income adopted by the AO, being one of the recognized methods of determination of income, could not be found fault - not find any perversity in the finding - no substantial questions of law
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