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 ...
West Bengal Industrial Promotion Assistance to Industrial Enterprises (scheme) - The purpose of the scheme as spelt out is for encouraging manufacturing activities expansion etc. which would go to generate direct and indirect employment in the state. - Thus, any interpretation which is given which will stultify the objects of the schemes has to be frowned upon. - the bonafides of the appellant have not been doubted by the respondents, the eligibility is also not in dispute and if that be a factual position on account of a technical ground such incentive or benefit extended by the Government should not be denied. - HC
West Bengal Industrial Promotion Assistance to Industrial Enterprises (scheme) - The purpose of the scheme as spelt out is for encouraging manufacturing activities expansion etc. which would go to generate direct and indirect employment in the state. - Thus, any interpretation which is given which will stultify the objects of the schemes has to be frowned upon. - the bonafides of the appellant have not been doubted by the respondents, the eligibility is also not in dispute and if that be a factual position on account of a technical ground such incentive or benefit extended by the Government should not be denied. - HC
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