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...
Understatement of income on account of sale of energy - change in method of accounting of sales realization - if action of Ld. A.O and the Ld. CIT(A) in adding on alleged account of booking sale on accrual basis is accepted, it would amount to double taxation as the appellant company has changed the method from cash to accrual in following year and has offered to tax additional revenue - AT
Understatement of income on account of sale of energy - change in method of accounting of sales realization - if action of Ld. A.O and the Ld. CIT(A) in adding on alleged account of booking sale on accrual basis is accepted, it would amount to double taxation as the appellant company has changed the method from cash to accrual in following year and has offered to tax additional revenue - AT
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