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...
Disallowance of premium payable on redemption of debentures - addition on account of claim of premium on non-convertible debentures on proportionate basis - the moment the debentures were issued, the liability had arisen against the assessee which would constitute on expenditure allowable u/s 37 - Claim on proportionate basis cannot be disallowed - AT
Disallowance of premium payable on redemption of debentures - addition on account of claim of premium on non-convertible debentures on proportionate basis - the moment the debentures were issued, the liability had arisen against the assessee which would constitute on expenditure allowable u/s 37 - Claim on proportionate basis cannot be disallowed - AT
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