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...
Disallowance u/s.40A(3) - expenses towards air ticket and hotel expenses in cash in excess of prescribed limit u/s.40A(3) - there is merit in arguments of the assessee that it has acted only as agent for his customers and has booked air ticket on behalf of its customers, because it is general practice in this kind of industry that tour operators will collect money from its customers and in turn, make cash payments for booking air ticket, because airlines generally does not accept cheque payments, other than cash payment or on line payment. Therefore, this fact needs to be verified from the Assessing Officer to ascertain fact with regard to arguments of the assessee that it has made cash payment to airlines on behalf of its customers as their agent and thus, same needs to be outside scope of section 40A(3). - AT
Disallowance u/s.40A(3) - expenses towards air ticket and hotel expenses in cash in excess of prescribed limit u/s.40A(3) - there is merit in arguments of the assessee that it has acted only as agent for his customers and has booked air ticket on behalf of its customers, because it is general practice in this kind of industry that tour operators will collect money from its customers and in turn, make cash payments for booking air ticket, because airlines generally does not accept cheque payments, other than cash payment or on line payment. Therefore, this fact needs to be verified from the Assessing Officer to ascertain fact with regard to arguments of the assessee that it has made cash payment to airlines on behalf of its customers as their agent and thus, same needs to be outside scope of section 40A(3). - AT
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