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...
Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by the assessee for non applicability of rule 8D(2)(iii) for rigid disallowance appears to be in congruity with market practice - not a fit case for resorting to double disallowance of similar expenditure
Disallowance u/s 14A r.w.r. 8D - in the case of mutual funds, administrative and managerial expenses are factored in the investments itself - the explanation offered by the assessee for non applicability of rule 8D(2)(iii) for rigid disallowance appears to be in congruity with market practice - not a fit case for resorting to double disallowance of similar expenditure
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