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...
Disallowance u/s 40A(3) read with Rule 6DD - expenses incurred in cash - payment through agent - There is no finding of the Ld.CIT(A) to the effect that the agent was not genuine .Further it is a fact on record that the agent had appeared before the AO and confirmed the said fact to him that he had acted as agent for the assessee - the situation envisaged in clause (k) of Rule 6DD is clearly satisfied - AT
Disallowance u/s 40A(3) read with Rule 6DD - expenses incurred in cash - payment through agent - There is no finding of the Ld.CIT(A) to the effect that the agent was not genuine .Further it is a fact on record that the agent had appeared before the AO and confirmed the said fact to him that he had acted as agent for the assessee - the situation envisaged in clause (k) of Rule 6DD is clearly satisfied - AT
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