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...
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Penalty u/s 271B - non-filing of Tax audit report u/sec. 44AB of the Act within the due date under section 139(1) - Due to technical issues and pressure of work, the assessee firm could not file their return of income within the due date specified under section 139(1) - Thus the delay is filling is not a wanton act and the explanations has a reasonable cause. - Penalty directed to be deleted - AT
Penalty u/s 271B - non-filing of Tax audit report u/sec. 44AB of the Act within the due date under section 139(1) - Due to technical issues and pressure of work, the assessee firm could not file their return of income within the due date specified under section 139(1) - Thus the delay is filling is not a wanton act and the explanations has a reasonable cause. - Penalty directed to be deleted - AT
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