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...
Penalty u/s 271(1)(c) - Penalty order did not specify the particular limb under which penalty u/s 271(1)(c) is levied. AO has not specified that penalty is either levied for furnishing inaccurate particulars of income or for concealing the income. The AO himself is not clear that penalty is either levied for concealment of income or for furnishing inaccurate particulars - No penalty - AT
Penalty u/s 271(1)(c) - Penalty order did not specify the particular limb under which penalty u/s 271(1)(c) is levied. AO has not specified that penalty is either levied for furnishing inaccurate particulars of income or for concealing the income. The AO himself is not clear that penalty is either levied for concealment of income or for furnishing inaccurate particulars - No penalty - AT
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