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 14A - Whether there is no tax free income earned during the year ? - To attract the provisions of Section 14A of the Act, 1961, it is necessary that the assessee should have earned any exempt income. If the assessee has not earned an exempt income and has not claimed so in his return of income, then the provisions of Section 14A would not be applicable. - HC
Disallowance u/s 14A - Whether there is no tax free income earned during the year ? - To attract the provisions of Section 14A of the Act, 1961, it is necessary that the assessee should have earned any exempt income. If the assessee has not earned an exempt income and has not claimed so in his return of income, then the provisions of Section 14A would not be applicable. - HC
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