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...
TDS u/s 194C - Addition u/s 40(a)(ia) - assessee has violated the provisions of Section 40(a)(ia) of the Act for not deducting & depositing the TDS - The amendment is applicable for the assessment year 2005-06, i.e. it is prospective in nature and not retrospective - Additions confirmed - AT
TDS u/s 194C - Addition u/s 40(a)(ia) - assessee has violated the provisions of Section 40(a)(ia) of the Act for not deducting & depositing the TDS - The amendment is applicable for the assessment year 2005-06, i.e. it is prospective in nature and not retrospective - Additions confirmed - AT
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