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 ...
Approval of Trust u/s.80G(5) - To be effective from the first date of Financial Year or from the date of approval - approval was granted provisionally as on 23.09.2021 - assessee is entitled for approval w.e.f. 01.04.2021 and not from 23.09.2021. The provisions of the acts are clear and there is no ambiguity about it. - AT
Approval of Trust u/s.80G(5) - To be effective from the first date of Financial Year or from the date of approval - approval was granted provisionally as on 23.09.2021 - assessee is entitled for approval w.e.f. 01.04.2021 and not from 23.09.2021. The provisions of the acts are clear and there is no ambiguity about it. - AT
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