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 u/s 68 - loans from relatives through banking channel - it is also not in dispute that cash deposits were made in the bank account of the creditor just before advancing the loan and no explanation was forthcoming before the authorities below - the onus of proving the source of a sum of money found to have been received by the assessee is on him and if he disputes the liability for tax - addition sustained
Addition u/s 68 - loans from relatives through banking channel - it is also not in dispute that cash deposits were made in the bank account of the creditor just before advancing the loan and no explanation was forthcoming before the authorities below - the onus of proving the source of a sum of money found to have been received by the assessee is on him and if he disputes the liability for tax - addition sustained
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