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...
Penalty u/s 271(1)(c) - income declared duty survey - voluntary delcaration or not - it is not a case wherein a disclosure was voluntarily made, indeed the assessee accepted the differential amount of business profit earned by him only after the same was brought to surface owing to survey action u/s 133A otherwise actual business profits would have remained un-assessed and untaxed, if survey action could not have taken place - Penalty sustained - AT
Penalty u/s 271(1)(c) - income declared duty survey - voluntary delcaration or not - it is not a case wherein a disclosure was voluntarily made, indeed the assessee accepted the differential amount of business profit earned by him only after the same was brought to surface owing to survey action u/s 133A otherwise actual business profits would have remained un-assessed and untaxed, if survey action could not have taken place - Penalty sustained - AT
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