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 ...
Non deduction of TDS - disallowance u/s 40(a)(iii) - the amount paid as foreign allowances to the seconded personal is not liable for deduction of tax as they continue to be the employees on the roll of the member oil companies - HC
Non deduction of TDS - disallowance u/s 40(a)(iii) - the amount paid as foreign allowances to the seconded personal is not liable for deduction of tax as they continue to be the employees on the roll of the member oil companies - HC
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