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 ...
Penalty u/s 271(1)(c) - Additions based on difference in TDS statement (Form 26AS) - assessee failed to submit reconciliation between the books of account and Form 26AS before the AO either during assessment proceedings or during the penalty proceeding or even before the first appellate authority and even before at the time of hearing of the instant appeal - penalty upheld
Penalty u/s 271(1)(c) - Additions based on difference in TDS statement (Form 26AS) - assessee failed to submit reconciliation between the books of account and Form 26AS before the AO either during assessment proceedings or during the penalty proceeding or even before the first appellate authority and even before at the time of hearing of the instant appeal - penalty upheld
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