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 ...
Restoration of cross objection appeal - Dismissal of appeal of the revenue on low tax effect - consequently cross objections of the assessee were also dismissed - the issue to be decided in the CO was an issue independent of the appeal filed by the Revenue. In such cases, the CO cannot be dismissed simply on the ground of dismissal of the appeal by the revenue involving low tax effect. - AT
Restoration of cross objection appeal - Dismissal of appeal of the revenue on low tax effect - consequently cross objections of the assessee were also dismissed - the issue to be decided in the CO was an issue independent of the appeal filed by the Revenue. In such cases, the CO cannot be dismissed simply on the ground of dismissal of the appeal by the revenue involving low tax effect. - AT
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