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 ...
Revision u/s 263 - Deduction U/s. 35D - effect of omission of word ‘industrial’ by the Finance Act, 2008 w.e.f 1/04/2009 - expenses incurred prior to 1/04/2009 - since assessee has fulfilled all the conditions stipulated under the Act for the residual period, there is no error in the order of the Ld. AO granting deduction - CIT is not right in his rem to invoke the revision provisions
Revision u/s 263 - Deduction U/s. 35D - effect of omission of word ‘industrial’ by the Finance Act, 2008 w.e.f 1/04/2009 - expenses incurred prior to 1/04/2009 - since assessee has fulfilled all the conditions stipulated under the Act for the residual period, there is no error in the order of the Ld. AO granting deduction - CIT is not right in his rem to invoke the revision provisions
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