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 of unexplained credit u/s 68 - assessee could not produce the party for examination before AO or CIT(A) - balance sheet of the lender clearly shows that the lender have deployed funds are non income producing funds, it does not result into any revenue to that company. The lender clearly is a paper company and nothing more than that - failed to discharge its initial onus as cast upon it u/s 68 - addition sustained
Addition of unexplained credit u/s 68 - assessee could not produce the party for examination before AO or CIT(A) - balance sheet of the lender clearly shows that the lender have deployed funds are non income producing funds, it does not result into any revenue to that company. The lender clearly is a paper company and nothing more than that - failed to discharge its initial onus as cast upon it u/s 68 - addition sustained
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