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 ...
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
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