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 ...
Addition u/s 69C - Unexplained expenses/premium - assessee did not furnish the source of payment of such expenses/premium - The case of assessee throughout the proceedings was that she is not having sufficient income. The expenses incurred by the other co-owners on her behalf and that no such similar addition was made in case of other co-owners, on whose behalf similar expenses were incurred by other co-owners. - It is settled law that the assessee cannot be treated as indifferently in respect of expenses or treatment of capital gain. - Additions deleted - AT
Addition u/s 69C - Unexplained expenses/premium - assessee did not furnish the source of payment of such expenses/premium - The case of assessee throughout the proceedings was that she is not having sufficient income. The expenses incurred by the other co-owners on her behalf and that no such similar addition was made in case of other co-owners, on whose behalf similar expenses were incurred by other co-owners. - It is settled law that the assessee cannot be treated as indifferently in respect of expenses or treatment of capital gain. - Additions deleted - AT
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