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...
Refund of excess amount of Duty and interest paid - principles of unjust enrichment - The refund here, in this case, is claimed for a few years only and just by referring to one year’s Books of Account, it cannot be concluded that the expenditure having not been carried forward, the same is not considered as a receivable. In any case, nothing turns in so far as taxation is concerned on a mere accounting treatment. - AT
Refund of excess amount of Duty and interest paid - principles of unjust enrichment - The refund here, in this case, is claimed for a few years only and just by referring to one year’s Books of Account, it cannot be concluded that the expenditure having not been carried forward, the same is not considered as a receivable. In any case, nothing turns in so far as taxation is concerned on a mere accounting treatment. - AT
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