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...
Undisclosed income of the assessee for the purpose of Chapter XIV B of the Income Tax Act - when section 158BB(3) is read with section 158B(b), which defines undisclosed income, we reach the conclusion that for income to be considered as disclosed income, the same should have been disclosed in the return filed by the assessee before the search or requisition - there is no question of law much less substantial question of law raised in favour of the assessee - HC
Undisclosed income of the assessee for the purpose of Chapter XIV B of the Income Tax Act - when section 158BB(3) is read with section 158B(b), which defines undisclosed income, we reach the conclusion that for income to be considered as disclosed income, the same should have been disclosed in the return filed by the assessee before the search or requisition - there is no question of law much less substantial question of law raised in favour of the assessee - HC
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