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 ...
Disallowance of loss of trading in commodity exchange - set off of loss - there is no finding by both the lower authorities challenging the genuineness of the commodity trading transactions entered during the year - It is true that it has been disclosed under head income from other source but according to Section 71(1) of the Act assessee is entitled to set off from income under the head Business & profession and income from other sources
Disallowance of loss of trading in commodity exchange - set off of loss - there is no finding by both the lower authorities challenging the genuineness of the commodity trading transactions entered during the year - It is true that it has been disclosed under head income from other source but according to Section 71(1) of the Act assessee is entitled to set off from income under the head Business & profession and income from other sources
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