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...
Search u/s 132 - Entitlement refund of the seized cash which is otherwise declared ‘unaccounted money’ and taxed in the hands of the searched person - This Court does not find any fault with the department of having refused to release the seized amount at the relevant point of time or even the refund thereafter. At the same time, declaring the income in the case of the writ- applicant being not taxable, will not ipso facto result into refund of the seized cash, which has otherwise been realized from the searched person. - HC
Search u/s 132 - Entitlement refund of the seized cash which is otherwise declared ‘unaccounted money’ and taxed in the hands of the searched person - This Court does not find any fault with the department of having refused to release the seized amount at the relevant point of time or even the refund thereafter. At the same time, declaring the income in the case of the writ- applicant being not taxable, will not ipso facto result into refund of the seized cash, which has otherwise been realized from the searched person. - HC
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