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 ...
Addition of notional interest income - the Income Tax Officer (ITO) cannot decide affairs of businessman as to how the businessman should incur the expenses or earn the interest. It is the sole discretion of businessman to manage its affairs and not the ITO. - Additions deleted - AT
Addition of notional interest income - the Income Tax Officer (ITO) cannot decide affairs of businessman as to how the businessman should incur the expenses or earn the interest. It is the sole discretion of businessman to manage its affairs and not the ITO. - Additions deleted - AT
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