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 ...
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
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