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 ...
Penalty u/s 271(1)(c) - tax u/s 115JB - assessee’s claim was that it was falling u/s 115JA and duly supported by the certificate of the auditors - If the claim was wrong the responsibility was that of the auditor who duly certified the same - assessee cannot be visited with penalty for the mistake of its consultant/auditor - no penalty
Penalty u/s 271(1)(c) - tax u/s 115JB - assessee’s claim was that it was falling u/s 115JA and duly supported by the certificate of the auditors - If the claim was wrong the responsibility was that of the auditor who duly certified the same - assessee cannot be visited with penalty for the mistake of its consultant/auditor - no penalty
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