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...
Addition of loan creditors - loan from farmers (having agriculture income) - AO has categorically mentioned that all of them are uneducated and having meagre agricultural land and some of them are having savings account with no balance - there is no satisfactory evidence about the credit worthiness of the creditors. We are of the view that the assessee failed to establish about the genuineness of the loan transactions except filing the affidavits. - Additions confirmed. - AT
Addition of loan creditors - loan from farmers (having agriculture income) - AO has categorically mentioned that all of them are uneducated and having meagre agricultural land and some of them are having savings account with no balance - there is no satisfactory evidence about the credit worthiness of the creditors. We are of the view that the assessee failed to establish about the genuineness of the loan transactions except filing the affidavits. - Additions confirmed. - AT
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