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...
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
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