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...
Addition u/s 69A - unexplained cash deposit - CIT(A) when recorded that without borrowing or having opening cash balance, there is no way the cash deposits for the respective years can be explained through salary and by the assessee, missed the aspect of the assessee holding sufficient opening balance for the respective years. With this view of the matter we find it difficult to sustain the impugned orders. - AT
Addition u/s 69A - unexplained cash deposit - CIT(A) when recorded that without borrowing or having opening cash balance, there is no way the cash deposits for the respective years can be explained through salary and by the assessee, missed the aspect of the assessee holding sufficient opening balance for the respective years. With this view of the matter we find it difficult to sustain the impugned orders. - AT
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