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 ...
Short Term Capital Gain arising out of transfer of equity shares - FCCBs/GDRs which were subsequently converted to equity shares - cost of acquisition of underlying shares - whether capital gain has to be computed by adopting the cost of acquisition of the GDRs/FCCBs under clause 7(3) and 7(4) of the 1993 scheme or it has to be computed under section 49(2A) r.w.s. 47(x) and 47(xa) of the Act, as held by the Departmental Authorities? - To be computed as per the clause 7(3) and 7(4) of the 1993 scheme - AT
Short Term Capital Gain arising out of transfer of equity shares - FCCBs/GDRs which were subsequently converted to equity shares - cost of acquisition of underlying shares - whether capital gain has to be computed by adopting the cost of acquisition of the GDRs/FCCBs under clause 7(3) and 7(4) of the 1993 scheme or it has to be computed under section 49(2A) r.w.s. 47(x) and 47(xa) of the Act, as held by the Departmental Authorities? - To be computed as per the clause 7(3) and 7(4) of the 1993 scheme - AT
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