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 ...
Assessment u/s 153A - Addition u/s 41(1) - No material was recovered during search which could have been treated as incriminating material and would be a base for supporting the action u/s 153(C) - the addition on account of Cessation of liability u/sn 41(1) is illegal, in valid and not sustainable in the eye of law and If such course is permitted it would amount to reopening assessment without any new material - not permissible
Assessment u/s 153A - Addition u/s 41(1) - No material was recovered during search which could have been treated as incriminating material and would be a base for supporting the action u/s 153(C) - the addition on account of Cessation of liability u/sn 41(1) is illegal, in valid and not sustainable in the eye of law and If such course is permitted it would amount to reopening assessment without any new material - not permissible
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