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...
Estimation of income from the business of plying of buses - The deposit of the specified bank notes is about 5% of the total turnover of the assessee. When the AO himself has estimated the income of the assessee at 2.25%, it would be farfetched even presumed that 5% of the assessee’s turnover could be an undisclosed income of the assessee from the operation of the contracted Government buses. - AT
Estimation of income from the business of plying of buses - The deposit of the specified bank notes is about 5% of the total turnover of the assessee. When the AO himself has estimated the income of the assessee at 2.25%, it would be farfetched even presumed that 5% of the assessee’s turnover could be an undisclosed income of the assessee from the operation of the contracted Government buses. - AT
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