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 ...
TDS u/s 192 on the perquisite - underreporting of value of perquisite - FMV of shares to determine the value of perquisites in respect of exercising of option under ESOP granted to the employee of the company - department has accepted the quantum of perquisite in the hands of employee-director - revenue appeal dismissed - AT
TDS u/s 192 on the perquisite - underreporting of value of perquisite - FMV of shares to determine the value of perquisites in respect of exercising of option under ESOP granted to the employee of the company - department has accepted the quantum of perquisite in the hands of employee-director - revenue appeal dismissed - AT
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