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 ...
TP Adjustment - adjustment on account of AMP expenditure - We are unable to accept the said contention of the learned counsel for the Revenue that since the Assessee herein is a ‘distributor’ for its AE, the corollary of this fact is that there exists an international transaction with respect to AMP expenditure, incurred by the Assessee. - HC
TP Adjustment - adjustment on account of AMP expenditure - We are unable to accept the said contention of the learned counsel for the Revenue that since the Assessee herein is a ‘distributor’ for its AE, the corollary of this fact is that there exists an international transaction with respect to AMP expenditure, incurred by the Assessee. - HC
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