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...
Deduction u/s 80IC - interest received on a fixed deposit - Insofar as Appellant is concerned that the AO could not have, in such circumstances, treated the interest accrued on fixed deposit as business income, is a submission which has merit. However, that said, this would not impact the tax burden insofar as the appellant/assessee is concerned; what would change, perhaps, would only be the head under which such income is made amenable to tax. - Petition dismissed - HC
Deduction u/s 80IC - interest received on a fixed deposit - Insofar as Appellant is concerned that the AO could not have, in such circumstances, treated the interest accrued on fixed deposit as business income, is a submission which has merit. However, that said, this would not impact the tax burden insofar as the appellant/assessee is concerned; what would change, perhaps, would only be the head under which such income is made amenable to tax. - Petition dismissed - HC
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