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...
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
Deduction u/s. 80JJAA - claim made was disallowed to the assessee because it was not included in the return of income filed by the assessee - Assessee did not have the opportunity to raise the contention before the AO as its return was processed by CPC, Bangalore and intimation was issued u/s. 143(1) and, therefore, the assessee had no opportunity to make a fresh claim by way of filing a revised return before the CPC, Bangalore since the process is completed. The claim made by the assessee at the first appellate stage is an allowable claim. - AT
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