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 ...
Income estimation applying GP Rate - AO neither pointed out any defect in the books of accounts nor rejected u/s 145(2) - addition without verification of various expenditure and giving any benefit of difference in the business model, product dealt with, geographical area operated in etc. and merely compared the GP of other entities is not permissible
Income estimation applying GP Rate - AO neither pointed out any defect in the books of accounts nor rejected u/s 145(2) - addition without verification of various expenditure and giving any benefit of difference in the business model, product dealt with, geographical area operated in etc. and merely compared the GP of other entities is not permissible
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