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 ...
TDS u/s 192 or 194J - payment to the consultant-doctors and retainer-doctors - Whether there was employer- employee relation between both the parties? - Certain clauses in contract with retainers which gave the erroneous impression to the Ld. AO of creating an employer-employee relationship has been explained by the assessee that they do not create such a relationship. The explanation of the assessee has unanimously been accepted by various judicial pronouncements. - TDS was rightly deducted u/s 194J - AT
TDS u/s 192 or 194J - payment to the consultant-doctors and retainer-doctors - Whether there was employer- employee relation between both the parties? - Certain clauses in contract with retainers which gave the erroneous impression to the Ld. AO of creating an employer-employee relationship has been explained by the assessee that they do not create such a relationship. The explanation of the assessee has unanimously been accepted by various judicial pronouncements. - TDS was rightly deducted u/s 194J - AT
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