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 ...
Unexplained share capital - transactions were made through banking channel and existence of persons in whose names shares had been issued was shown - burden shifted on the revenue to establish that the investment came from the assessee company itself - HC
Unexplained share capital - transactions were made through banking channel and existence of persons in whose names shares had been issued was shown - burden shifted on the revenue to establish that the investment came from the assessee company itself - HC
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