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 ...
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
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