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 ...
Addition of unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
Addition of unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
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