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 ...
TDS u/s 194C - payment to works contract - MoU reveals that the work carried out by the developer / contractor was as per the requirements of the assessee - Demand confirmed - On alternative argument, purchase of immovable property, by an assessee from a developer, was otherwise for TDS at 1%. We therefore agree CIT(A) that the assessee was liable to deduct TDS. Assessee therefore cannot be exonerated from the charge of being ‘assessee in default’.- AT
TDS u/s 194C - payment to works contract - MoU reveals that the work carried out by the developer / contractor was as per the requirements of the assessee - Demand confirmed - On alternative argument, purchase of immovable property, by an assessee from a developer, was otherwise for TDS at 1%. We therefore agree CIT(A) that the assessee was liable to deduct TDS. Assessee therefore cannot be exonerated from the charge of being ‘assessee in default’.- AT
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