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...
Power of CIT for enhancement u/s 251 - those items, which were not part of the ROI, Assessment proceedings or Assessment order, cannot be considered by the ld CIT (A) for enhancement. Right course would have been to intimate ld AO to issue notice u/s 148 of the Act or to propose revision u/s 263 of the Act. - AT
Power of CIT for enhancement u/s 251 - those items, which were not part of the ROI, Assessment proceedings or Assessment order, cannot be considered by the ld CIT (A) for enhancement. Right course would have been to intimate ld AO to issue notice u/s 148 of the Act or to propose revision u/s 263 of the Act. - AT
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