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 ...
Revision u/s 263 by CIT - As per PCIT AO fails to examine the issue on increase in share premium in light of provisions of section 56(2)(vii), although, the assessee has made huge cash deposits during demonetization period, the AO has not verified the issue in light of SOP issued by CBDT for verification - Revision proceedings sustained - AT
Revision u/s 263 by CIT - As per PCIT AO fails to examine the issue on increase in share premium in light of provisions of section 56(2)(vii), although, the assessee has made huge cash deposits during demonetization period, the AO has not verified the issue in light of SOP issued by CBDT for verification - Revision proceedings sustained - AT
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