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...
Penalty u/s 271AA - failure of the assessee to report the intentional transactions - As seen that the AO wrongly applied the amended Section 271AA which is effective from the assessment year 2012-13. That apart, for the delay in furnishing an information, the same could be covered under Section 271G of the Act. However, the AO dropped the proposal to impose penalty under Section 271G of the Act. - HC
Penalty u/s 271AA - failure of the assessee to report the intentional transactions - As seen that the AO wrongly applied the amended Section 271AA which is effective from the assessment year 2012-13. That apart, for the delay in furnishing an information, the same could be covered under Section 271G of the Act. However, the AO dropped the proposal to impose penalty under Section 271G of the Act. - HC
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