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 ...
Authorization for search - Status of assessee - existence of AOP/BOI - evidence of existence - after the amendment of the Act by insertion of Section 292 CC with retrospective effect from 1.4.1976, even if the authorization had been issued in the joint names of several persons, assessment in the individual names can be made - HC
Authorization for search - Status of assessee - existence of AOP/BOI - evidence of existence - after the amendment of the Act by insertion of Section 292 CC with retrospective effect from 1.4.1976, even if the authorization had been issued in the joint names of several persons, assessment in the individual names can be made - HC
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