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 ...
Ad-hoc disallowance of 25% of construction expenses - AO rejected the books of accounts u/s 145 - the income of the assessee should be based on average GP declared by the assessee in the preceding years or the prevailing GP in the same trade or business - disallowance of expenses is not a permissible course of action.
Ad-hoc disallowance of 25% of construction expenses - AO rejected the books of accounts u/s 145 - the income of the assessee should be based on average GP declared by the assessee in the preceding years or the prevailing GP in the same trade or business - disallowance of expenses is not a permissible course of action.
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