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...
Addition of pre-operative expenditure - revenue or capital expenditure - expenses are only to enhance the existing portfolio of the assessee and to increase its existing production capacity - even there is no denial of the fact that the expenditure claimed by the assessee is otherwise revenue in nature and not relating to the set up of the plant - duly allowable
Addition of pre-operative expenditure - revenue or capital expenditure - expenses are only to enhance the existing portfolio of the assessee and to increase its existing production capacity - even there is no denial of the fact that the expenditure claimed by the assessee is otherwise revenue in nature and not relating to the set up of the plant - duly allowable
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