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 ...
Disallowance of claim of ‘surrender right fee’ - allowable business expenditure or not? - the assessee was not able to get necessary approvals and clause 3.4 provided that upon termination of the agreement as a result of failure to receipt approvals all advances granted by buyer to seller have to be returned in 30 days. - The amount to settle for an agreement allowed as expenditure - AT
Disallowance of claim of ‘surrender right fee’ - allowable business expenditure or not? - the assessee was not able to get necessary approvals and clause 3.4 provided that upon termination of the agreement as a result of failure to receipt approvals all advances granted by buyer to seller have to be returned in 30 days. - The amount to settle for an agreement allowed as expenditure - AT
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