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...
Disallowance u/s.40(a)(ia) - Failure to deduct TDS - Scope of amendment - if a statute is curative of the previous law, retrospective operation is generally intended. - AO directed to restrict the 100% disallowance confirmed by the CIT(A) to the extent of 30% only taking into account the actual claim of the assessee in its profit and loss account. - AT
Disallowance u/s.40(a)(ia) - Failure to deduct TDS - Scope of amendment - if a statute is curative of the previous law, retrospective operation is generally intended. - AO directed to restrict the 100% disallowance confirmed by the CIT(A) to the extent of 30% only taking into account the actual claim of the assessee in its profit and loss account. - AT
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