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 271E - violation of the provision of section 269T - assessee has repaid the loans and advances received from various creditors otherwise than by crossed cheque - sufficient and reasonable cause for repayment of the loan to the directors and shareholders - the assessee has demonstrated that transactions were genuine with relevant documents. It is a mere technical violation and there is no loss to the revenue - No penalty - AT
Penalty u/s 271E - violation of the provision of section 269T - assessee has repaid the loans and advances received from various creditors otherwise than by crossed cheque - sufficient and reasonable cause for repayment of the loan to the directors and shareholders - the assessee has demonstrated that transactions were genuine with relevant documents. It is a mere technical violation and there is no loss to the revenue - No penalty - AT
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