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 ...
Disallowance of interest expenses - assessee has made contradictory submissions before the learned CIT (A) and has not furnished the required details of the interest expenses to justify that the interest cost was incurred in the course of the business. Thus in the absence of sufficient documentary evidence about the interest expenses on the borrowed fund whether the same was utilized for the purpose of business, claim of assessee cannot be allowed- AT
Disallowance of interest expenses - assessee has made contradictory submissions before the learned CIT (A) and has not furnished the required details of the interest expenses to justify that the interest cost was incurred in the course of the business. Thus in the absence of sufficient documentary evidence about the interest expenses on the borrowed fund whether the same was utilized for the purpose of business, claim of assessee cannot be allowed- AT
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